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full-time job. He became a full-time minister in 1980 and
continued his full-time ministry throughout the year at issue.
In 2001, petitioner Gail Vigil (Mrs. Vigil) was a homemaker.
Since 1987, petitioners have claimed they are exempt from
self-employment taxes on income from Mr. Vigil’s work as a
minister, pursuant to section 1402(e).
In 1996, apparently during the examination of petitioners’
1994 joint tax return, Mr. Vigil wrote a letter to the Internal
Revenue Service (IRS). Mr. Vigil stated that in 1987 he had
filed a Form 4361, Application for Exemption From Self-Employment
Tax for Use by Ministers, Members of Religious Orders and
Christian Science Practitioners, and that a copy of the approved
Form 4361 had been returned to him. Mr. Vigil requested that
another copy of the approved application be sent to him and
enclosed a copy of the signed (but unapproved) Form 4361 he
contends he filed in 1987. The IRS received his request and the
enclosed copy of the unapproved Form 4361 in May 1996. The IRS
searched its document and computer files but did not find any
record that Mr. Vigil had been approved for a ministerial
exemption or any record that Mr. Vigil had filed a request for a
ministerial exemption before 1996. The IRS requested that the
Social Security Administration (SSA) search its records and
learned that the SSA did not have any record of either the
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