David and Gail Vigil - Page 3




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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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