William C. Blakely and Bettie Blakely v. Commissioner of Internal Revenue

This case is an appeal from a decision by the United States Tax Court holding taxpayers William C. Blakely and Bettie Blakely responsible for deficiencies in their federal income taxes for the years 1976,1977 and 1978. Bettie Blakely is named in this action solely because she filed an income tax return jointly with her husband for the years in question. For brevity, this opinion will refer to the taxpayer appellants as “Blakely.”

At issue is the validity of a waiver which Blakely, a minister, signed in 1957 electing to participate in the social security system under the provisions for…