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minister seeking the exemption must file an application stating
that he is opposed, because of religious principles or
conscientious beliefs, to the acceptance of certain types of
public insurance, such as that provided by the Social Security
Act, attributable to his services as a minister. Sec.
1402(e)(1). This application must be filed within the specific
time limits set forth in section 1402(e)(3). Once properly
obtained, the exemption from self-employment tax is irrevocable
and remains effective for all succeeding taxable years. Sec.
1402(e)(4).
Section 1402(e)(3) provides that the application for
exemption must be filed on or before the later of the following
dates: (1) The due date of the return (including any extensions)
for the second taxable year for which the taxpayer has net
earnings from self-employment of $400 or more, any part of which
was derived from the performance of services as a minister, or
(2) the due date of the return (including any extensions) for his
second taxable year ending after 1967. Sec. 1402(e)(3); sec.
1.1402(e)-3A(a)(1), Income Tax Regs. This Court has consistently
held that the time limitations imposed by section 1402(e)(3) are
mandatory and taxpayers must strictly comply with them. Wingo v.
Commissioner, 89 T.C. 922, 930 (1987); Ballinger v. Commissioner,
78 T.C. 752, 757 (1982), affd. 728 F.2d 1287 (10th Cir. 1984);
Keaton v. Commissioner, T.C. Memo. 1993-365.
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