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In Williams v. Commissioner, T.C. Summary Opinion 1997-145,
this Court addressed petitioner's various arguments. We decided
the same issue which is before us in this case in favor of
respondent with respect to petitioner's 1993 taxable year. We
there held:
Although the income petitioner derived from his
handyman business may have enabled him to sustain his
ministry at Moss Bluff Church of Christ and to fulfill
the obligation of supporting his family, those reasons
or motives do not cause the handyman business to be
integral to the conduct of his ministry. Petitioner
failed to show that his self-employment income from the
handyman business was earned "with respect to services
performed by him as * * * [a] minister", as required
by section 1402(e).
* * * * * * *
Petitioner failed to present evidence to show that the
tenets or teachings of the Moss Bluff Church of Christ
are opposed to private or public insurance programs.
Petitioner further failed to show that he is a member
of any other recognized religious sect, or division
thereof, whose tenets or teachings oppose the
acceptance of private or public insurance benefits.
Moreover, petitioner failed to produce any evidence
that he completed and filed a Form 4029 with the IRS,
as required by the regulations, to qualify for an
exemption from self-employment tax under section
1402(g).
We find that this case is factually indistinguishable from
Williams v. Commissioner, supra. There has been no change in the
applicable law, and petitioner has not presented any additional
arguments. Accordingly, under the doctrine of collateral
estoppel, we hold that petitioner's earnings from his handyman
business are subject to self-employment tax under section 1401.
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