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Although petitioners timely filed applications for automatic
extension of time to file their Federal income tax returns,
petitioners untimely filed their joint Federal income tax returns
for 1985, 1990, and 1991. Petitioners’ 1985 joint Federal income
tax return was untimely filed on September 30, 1992.
Petitioners’ 1990 and 1991 joint Federal income tax returns were
untimely filed on February 8, 1993.
On petitioners’ 1990 and 1991 joint Federal income tax
returns, petitioners reported the compensation that petitioner
received as a senior pastor and as a district superintendent as
that of a self-employed minister. Petitioners therefore treated
the $10,605 and $19,314 in expenses relating to petitioner’s work
as a minister as fully deductible business expenses on Schedule C
of their respective Federal income tax returns.
For self-employment tax purposes, petitioners reported as
self-employment income total net income on the Schedule C’s of
$31,814 for 1990 and $31,365 for 1991, plus $3,600 for 1990 and
$7,500 for 1991. The latter two amounts apparently reflect
petitioners’ estimate, on their income tax returns, of the rental
value of the parsonages and of the additional amounts petitioner
designated and received in cash as relating to utility and other
household expenses of the parsonages. The total income that
petitioners reported for 1990 and 1991 as petitioner’s self-
employment income for petitioner’s work as a minister was $35,414
and $38,865, respectively.
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