William and Cathy A. Bennett - Page 3




                                         -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            





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  Next 

Last modified: March 27, 2008