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income. See sec. 1402(c)(2). There are exceptions to this
general rule, however, and one of the exceptions is relevant
here. The income earned by an individual in the performance of
services as an employee/minister of a church is subject to the
tax on self-employment income unless the individual files a
timely application for exemption. See sec. 1402(c)(2)(D),
(c)(4), (e). To be effective, the application must be timely,
and the time limitations set forth in the statute are mandatory
and strictly enforced. See Wingo v. Commissioner, 89 T.C. 922,
930 (1987); sec. 1.1402(e)-3A, Income Tax Regs.
For the years involved here, an application for exemption is
timely only if the "duly ordained, commissioned, or licensed
minister" files the application before the due date of the return
for the second taxable year for which the minister has net
earnings from self-employment of $400 or more, any part of which
was derived from the performance of services in the minister's
ministry. See sec. 1402(e)(2).
Petitioner's application for exemption from the self-
employment tax was filed on April 17, 1989. Petitioners argue
that the application, which was approved based upon the
information reported thereon, was timely because petitioner did
not perform services as a minister until he was ordained a deacon
on May 25, 1987. According to petitioners, providing services as
a licensed local pastor in previous years did not constitute the
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