Frank T. Olsen and Lois E. Olsen v. Commissioner of Internal Revenue

HARRISON L. WINTER, Chief Judge:

Frank Olsen appeals from a decision of the Tax Court upholding a deficiency assessment levied for his failure to pay the self-employment tax on his ministerial income for the years 1976 and 1977. T.C. Mem.Dec. (P-H) ¶ 82,340 (1982). Before us, he contends, as he did before the Tax Court, that the imposition of the self-employment tax on his ministerial income (a) violates his right to free exercise of religion, and (b) violates his right to due process because he was denied a second opportunity to file for an exemption from the tax given to members of certain…