- 2 - Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Respondent determined a $12,118 deficiency in petitioners’ 2001 Federal income tax, a $3,029.50 addition to tax pursuant to section 6651(a)(1) for failing to file a timely 2001 tax return, and a $2,423.60 accuracy-related penalty pursuant to section 6662. The issues for decision are: (1) Whether petitioners are liable for self-employment tax on income petitioner David Vigil (Mr. Vigil) earned as a minister in 2001; (2) whether petitioners are entitled to certain claimed deductions on Schedule C, Profit or Loss From Business; (3) whether petitioners are liable for the failure-to-file addition to tax under section 6651(a)(1); and (4) whether petitioners are liable for the accuracy-related penalty under section 6662. Background The parties stipulated some of the facts, and they are so found. We incorporate the stipulation of facts and the attached exhibits herein by this reference. Petitioners resided in Norwalk, California, when they filed the petition. On January 1, 1979, the Independent Pentecostal Church granted Mr. Vigil a license as a minister. Mr. Vigil’s primary calling has been to minister on Indian reservations. During 1979, Mr. Vigil worked part time as a minister and also had aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008