-4-
not include statements certifying that petitioner was
opposed to the acceptance of public retirement
insurance and that petitioner had informed the Neenach
Bible Church of his opposition thereto; and
(4) with the filing of petitioners’ 2002 joint Federal
income tax return, petitioner did not report or pay any
self-employment taxes on the $10,461 ministerial income
he received in 2002.
On August 27, 2003, respondent mailed to petitioners a
letter relating to petitioners’ 2002 Federal income tax return,
stating that the due date for petitioner to timely file a Form
4361 had been April 15, 2001, that the Form 4361 petitioner filed
with his 2002 tax return was therefore untimely, and that
petitioner’s request for a ministerial exemption from self-
employment taxes was not approved.
On October 13, 2005, respondent mailed to petitioners a
notice of deficiency relating to petitioners’ 2002 joint Federal
income taxes in which respondent determined a deficiency of
$1,620 based on self-employment taxes allegedly due on
petitioner’s 2002 net income as a minister.1
Discussion
Income earned by an individual in the performance of
services as a nonemployee, ordained, commissioned, and licensed
minister of a church is subject to self-employment taxes unless
1 The record herein does not indicate whether respondent
determined tax deficiencies against petitioner for self-
employment taxes relating to years prior to 2002.
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