- 2 -
The issue for decision for each year in issue is whether
income earned as a Methodist minister by John Michael Brannon is
subject to the tax on self-employment income. The resolution of
the issue depends upon whether Mr. Brannon submitted a timely
application for exemption from the tax on self-employment income,
which in turn depends upon whether the services he performed as a
licensed local pastor in the United Methodist Church constitute
the performance of services by a minister of a church within the
meaning of section 1402. Unless otherwise indicated, section
references are to the Internal Revenue Code in effect for the
years in issue.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioners are husband and wife. They filed a timely joint
Federal income tax return for each year in issue. At the time
the petition was filed, petitioners resided in Pike Road,
Alabama. References to petitioner are to John Michael Brannon.
On August 1, 1983, while enrolled as a student at Huntington
College, petitioner was licensed as a student local pastor for
the United Methodist Church (the Church). He was assigned to the
Trinity-Weoka Church in the Alabama-West Florida Conference
(Trinity-Weoka), which remained in his charge at least through
1990. Between 1985 and 1988, petitioner was enrolled at Emory
University Chandler School of Theology seminary in Atlanta.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011