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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 a
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