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election". The February 1992 Form 4361 was determined to be
untimely and was disapproved by the IRS on March 23, 1992.
Eventually, petitioners' Federal income tax return for the
year 1991 also came under examination by respondent. In the year
1991, petitioner earned and reported $32,069 from Word Outreach
Center for services performed as a minister. On their joint
individual Federal income tax return for 1991, however,
petitioners did not report self-employment tax on any of the
income received in connection with petitioner's services as a
minister. Respondent searched her records and found no
application for exemption other than the Form 4361 disapproved on
March 23, 1992. Having found no approved application for
exemption from self-employment tax, respondent determined that
the entire $32,069 received by petitioner during 1991 from Word
Outreach Center is subject to self-employment tax.
Discussion
Petitioners argue that they are exempt from self-employment
tax on petitioner's earnings as a minister. Respondent's
position is that petitioners have not timely filed for or
received an approved exemption from self-employment taxes. The
determinations of respondent are presumed to be correct, and
petitioners bear the burden of proving otherwise. Rule 142(a);
Welch v. Helvering, 290 U.S. 111, 115 (1933).
Section 1401(a) imposes on the self-employment income of
every individual a tax for old-age, survivors and disability
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