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During the years in issue, petitioner operated a piano
service and sales business. Petitioner has been self-employed in
this business since 1990 and has been self-employed in other
unidentified businesses since 1983. Petitioner reported the
income and expenses attributable to his piano service and sales
business on Schedules C for the years in issue. For each year,
along with other business expense deductions not in dispute,
petitioner deducted as "other expenses" the payments made to the
aforementioned religious organizations. Although petitioner
reported net profit on his Schedules C for 1990 and 1991,
petitioner did not file a Schedule SE, Computation of Social
Security Self-Employment Tax, or pay self-employment tax on the
amount of net profit earned from the business for either year.
On January 6, 1992, petitioner completed a Form 4029,
Application for Exemption from Tax on Self-employment Income and
Waiver of Benefits, and forwarded it to the Internal Revenue
Service. On the Form 4029 petitioner stated, in part:
I certify that I am and continuously have been a member
of Church of Jesus Christ, Terre Haute, Indiana, since
20 Feb 1977 and as a follower of the established
teachings of that group, I am conscientiously opposed
to accept any benefits of any private or public
insurance that makes payments in the event of death,
disability, old age, or retirement or makes payments
toward the cost of, or provides services for, medical
care. Public insurance includes any insurance system
established by the Social Security Act.
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