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taxpayer in Wingo v. Commissioner, supra, and concluded as follows:
To perform services in the control, conduct, and
maintenance of the church or organizations within the
church, the minister need only have some participation
in the conduct, control, and maintenance of the local
church or denomination. [Id. at 936; emphasis
supplied.]
During 1983 and 1984, as a licensed local pastor petitioner
served "in the control, conduct, and maintenance" of his charge,
that is, Trinity-Weoka, even though as a licensed local pastor he
might not have done so with respect to the Church as the
governing organization.
In 1983 and 1984, as a licensed local pastor, petitioner:
(1) Presided over the ministration of sacerdotal functions; (2)
conducted religious worship; and (3) served in the control,
conduct, and maintenance of his charge within the Church.
Therefore, during those years he performed services as a minister
within the meaning of section 1402. That being so, and because
for each of those years petitioner had net earnings of at least
$400 derived for the performance of services as a minister, to be
effective, his application for exemption from the tax on self-
employment income should have been filed prior to the due date of
his 1984 Federal income tax return. Because it was not so filed,
respondent's determination that petitioner's earnings as a
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