- 10 - Mr. Hairston: No. I am not opposed to the -- to that, as a religious issue, no. We were advised to -- by our accountant, to file for an exemption with the State, providing the State would allow it. And we asked the State to allow it, which they did. Although petitioner signed an exemption application stating that he is opposed to public insurance because of his religious principles, the Court finds petitioner's trial testimony to be more compelling. The application for exemption contained numerous significant mistakes, including the date that petitioner was ordained and the religious body that ordained petitioner. It is obvious that petitioner did not carefully review the application. In view of the significant mistakes made on the application, it is possible that petitioner did not even read the application, including the statement certifying that the applicant is opposed to public insurance, prior to signing the Form 4361. We hold that petitioner has failed to prove that he is opposed to public insurance as is required by section 1402(e)(1) in order to qualify for exemption from the self-employment tax. Petitioner is therefore liable for self-employment taxes for the taxable years 1988, 1989, and 1990.4 4 We note that for the taxable year 1990, petitioners are entitled to deduct from gross income one-half of their self- employment tax liability pursuant to sec. 164(f).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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