-3-
certifying that petitioner was opposed to acceptance of public
retirement insurance such as Social Security and that petitioner
had informed the Neenach Bible Church of his opposition to such
public retirement insurance. Lastly, reflected in the table
below is an indication of whether respondent acted on
petitioner’s Form 4361 or letter.
Petitioners’ Filed Tax Returns Included Statements
Filing Ministerial SE Taxes Related Opposing Informing Respondent’s
Year Date Income Paid 4361 LetterInsurance Church Action
1997 6/12/2000 1>$400 -0- Yes No Yes YesNot
processed
1998 4/15/1999 15,263 $4,191 No Yes No NoNot
processed
1999 4/15/2000 14,400 -0- Yes Yes Yes YesNot
processed
2000 Not filed - - - - - - -
2001 4/15/2002 10,727 -0- Yes Yes Yes YesNot
processed
2002 4/15/2003 10,461 -0- Yes No Yes YesDenied as
untimely2
1 Although there is some confusion as to the precise amount of ministerial
income reported on petitioners’ 1997 joint Federal income tax return, the parties
stipulated that petitioner in 1997 received as a minister net self-employment
income of $400 or more.
2 While it does not affect our decision, it is unclear why respondent did not
process petitioner’s Forms 4361 or letters for 1997, 1998, 1999, and 2001.
As reflected in the table above:
(1) In 1997, 1998, 1999, 2001, and 2002, petitioner
received net ministerial income of $400 or more, and
for 1998 petitioner reported and paid self-employment
taxes thereon;
(2) petitioners’ 1997 joint Federal income tax return
and the related Form 4361 were not filed until June 12,
2000;
(3) the letter petitioner filed with petitioners’ 1998
joint Federal income tax return on April 15, 1999, did
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Last modified: March 27, 2008