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performance of services as a minister within the meaning of
section 1402 because the authority of a local pastor is not as
extensive as the authority of an ordained deacon.
Respondent disagrees and argues that the services that
petitioner performed as a local pastor in 1983 and 1984
constituted the performance of services as a "licensed" minister,
even though petitioner was not yet an "ordained" minister.
Because petitioner earned more than $400 from the performance of
such services in those years (a point that is not in dispute),
respondent maintains that the application was not timely because
it was not filed by the due date of petitioner's 1984 Federal
income tax return.
Petitioners' argument that the period for filing the
application for exemption did not begin to run until the date of
his ordination, is incorrect. The phrase "duly ordained,
commissioned, or licensed minister", as used in the relevant
statutory scheme, is a disjunctive phrase. The statute applies
if the individual is either an ordained minister, a commissioned
minister, or a licensed minister. See Wingo v. Commissioner,
supra at 933; Salkov v. Commissioner, 46 T.C. 190, 197 (1966).
Whether an individual performs services as an ordained,
commissioned, or licensed minister depends upon the type of
services performed, not just on the official title of the person
performing those services. Consequently, we focus upon the
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