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insurance. Beginning with taxable years ending after 1967,
ordained ministers are automatically subject to the self-
employment tax with respect to services performed by them. Sec.
1402(c); see Peverill v. Commissioner, T.C. Memo. 1986-354.
Provided certain requirements are met, section 1402(e)
exempts from the self-employment tax, the self-employment income
of certain ministers and others. Under section 1402(e)(1), a
minister must file an application for exemption "in such form and
manner, and with such official, as may be prescribed by
regulations". The application must be filed no later than the
due date of the return (including any extension) for the second
taxable year for which the applicant had net earnings from self-
employment of at least $400, any part of which was from services
as a minister. Sec. 1402(e)(3).
Section 1.1402(e)-2A(b), Income Tax Regs., specifies that
the application must be made on Form 4361, in triplicate, with
the specified office of the Internal Revenue Service, within the
prescribed time limit.
The time limitations of section 1402(e) are mandatory and
must be complied with strictly. Treadway v. Commissioner, T.C.
Memo. 1984-153; Allinson v. Commissioner, T.C. Memo. 1979-405.
At trial petitioners testified that the appropriate Form 4361 was
timely filed by the due date of the return for the second taxable
year of petitioner's earnings from performing services as a
minister. According to petitioner, he filled out a Form 4361 on
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