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God on August 31, 1984. Further, line 5 states that 1985 and
1986 were the first 2 years in which petitioner had self-
employment earnings of at least $400 from services as a minister.
The application deadline, based on the information provided,
would be April 15, 1987, 2 years prior to the date that
petitioner actually filed the application. On petitioners' Form
4361, respondent placed a check in the box labeled "Disapproved
for exemption". The date beside respondent's representative's
signature is May 2, 1989.
In fact, petitioner was ordained by the Body of Christ
Church of Nashville, Tennessee, on May 17, 1987. Based upon
petitioners' testimony at trial and on returns filed by
petitioners, it appears that 1988 was the first year in which
petitioner had self-employment income of $400 or more earned from
services as a minister. Accordingly, the filing deadline for the
exemption application would have been on April 15, 1990, 1 year
after petitioners filed the application.
For the taxable years 1988, 1989, and 1990, petitioner
reported net earnings from self-employment; however, he did not
report self-employment tax with respect to those earnings.
Instead, for the taxable years 1988 and 1989, petitioner wrote
"Exempt Form 4361" on the line of the return relating to self-
employment tax. For the taxable year 1990, petitioner did not
enter anything on the line of the return relating to self-
employment tax.
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