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Respondent determined a deficiency of $3,311 in petitioner’s
1998 Federal income tax arising from petitioner’s failure to pay
self-employment tax. The issue is whether petitioner is exempt
from self-employment tax under section 1402(e). Petitioner
resided in Hammond, Indiana, at the time the petition was filed.
Petitioner earned a Master of Divinity degree in December of
1976 from the Lutheran School of Theology in Chicago. In 1977,
petitioner was ordained into the ministry by the Evangelical
Lutheran Church in America. Since his ordination, he served as a
minister of the Redeemer Lutheran Church in Bryant, Indiana.
Based on his religious beliefs and principles, petitioner
conscientiously objects to accepting public insurance. Thus, in
March of 1977, petitioner obtained a Form 4361, Application for
Exemption from Self-employment Tax for Use by Ministers, Members
of Religious Orders and Christian Science Practitioners, from the
Internal Revenue Service in Muncie, Indiana. Petitioner
completed and signed the Form 4361 in the presence of witnesses.
Petitioner mailed the Form 4361 to the Internal Revenue
Service in Cincinnati, Ohio. Respondent has no record that Form
4361 was filed. Petitioner does not have a copy of the completed
Form 4361. The General Instructions on Form 4361, Part G, state:
“Mail your application to the Internal Revenue Service Center for
the place where you live.” The instructions directed petitioner,
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Last modified: May 25, 2011