- 5 -
granted petitioner's application for exemption from self-
employment tax.
Included with petitioners' Federal income tax return for
each year in issue is a Schedule C on which petitioners reported
the earnings and expenses attributable to petitioner's ministry
as follows:
1987 1988 1989
Gross receipts $12,150 $13,783 $19,400
Car & truck exp. 4,511 4,786 4,993
Educ. exp. 1,523 440 -0-
Net profit 6,116 8,557 14,407
Petitioners did not treat the net profit for any year as net
earnings from self-employment.
In the notice of deficiency, respondent determined that the
services that petitioner provided as a minister during each year
in issue were provided as an employee of the Church and that the
income and expenses attributable to those services must be
reported accordingly. Respondent also determined that the income
that petitioner earned as a minister was subject to the tax on
self-employment income. Other adjustments made in the notice of
deficiency are not in dispute.
OPINION
Although petitioner's employment status as a Methodist
minister was at one time in dispute, the parties now agree that
the services that petitioner performed as a minister during the
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011