Wayne and June Ellen Hairston - Page 8

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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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