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religious order, sect, or division thereof, nor was he a
Christian Science practitioner. From approximately 1958 to 1973,
petitioner had been a member of the Amish church. In either 1972
or 1973, petitioner and several other members of the Amish church
were excommunicated because of differences over certain Biblical
teachings and doctrines. Petitioner has never been readmitted
into the Amish church.
In the notice of deficiency, respondent determined that
petitioner's net earnings from his three self-employment
activities during 1994 were subject to self-employment tax.
Petitioner's sole basis for his position is stated in his
trial memorandum as follows:
it is my sincere honest faith, and belief, that insurance
and security programs do work contrary to the teachings of
Jesus Christ. Jesus taught that we are not to take thought
for our life as to what we should eat or wear, but that we
rather sell what we have and give alms. * * * I do
understand Social Security to be designed and programed much
the same as insurance, and will provide for me in the
future, when perhaps I do have a need.
On that basis, petitioner objects to the payment of taxes on
self-employment.
Section 1401(a) imposes a tax on the self-employment income
of every individual for old age, survivors, and disability
insurance. Section 1401(b) imposes a tax on the self-employment
income of every individual for hospital insurance. In general,
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