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timely Form 4361 or equivalent letter with the required
certification statements, petitioner’s 2002 net income as a
minister does not qualify for exemption from self-employment
taxes.
The record before us does not establish that petitioner in
1980 filed a Form 4361. Petitioner’s evidence and testimony are
inconsistent as to petitioner’s alleged 1980 filing of a Form
4361. Petitioner produced no documentation to corroborate that
in 1980 he filed a Form 4361.
Respondent searched relevant files in respondent’s
Ministerial Unit in respondent’s Philadelphia Service Center,
which processes all Forms 4361 filed with respondent and which
maintains individual folders containing Forms 4361 relating to
petitioner and to other ministers. The folder relating to
petitioner does not contain any Form 4361 filed by petitioner in
1980. Respondent also conducted a search of his other files and
archives for petitioner’s allegedly filed Form 4361, but
respondent’s search yielded no Form 4361 filed by petitioner in
1980.
Petitioner relies on evidence from the Social Security
Administration (SSA) indicating that petitioner contributed to
Social Security and paid employment taxes for every year since
1973, except for 1980, 1981, 1982, 1989, 1997, 2001, 2002, and
2005. Petitioner alleges that the fact that he failed to pay
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