Ballinger v. Commissioner
United States Tax Court
P was duly ordained a minister in 1969. From 1973 through 1975, he received net earnings from self-employment of $ 400 or more derived from his performance of services as a minister, and he reported and paid self-employment taxes for those years.
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P was duly ordained a minister in 1969. From 1973 through 1975, he received net earnings from self-employment of $ 400 or more derived from his performance of services as a minister, and he reported and paid self-employment taxes for those years. After a change in belief based on further Biblical studies, he was ordained a second time in 1978 and then filed an application for exemption from self-employment tax pursuant to sec. 1402(e)(2), I.R.C. 1954. Held: 1. P filed an untimely application for exemption and it was properly denied by R; 2. P is liable for self-employment taxes for 1976,…
1Opinion of the Court
OPINION
Dawson, Judge:
In these consolidated cases, respondent determined the following deficiencies in petitioners’ Federal income taxes and additions to tax:
Additions to tax1
Docket No. Year Deficiency Sec. 6651(a) Sec. 6653(a)
773-81 1974 . $302.00 0 0
773-81 1975 98.00 0 0
773-81 1976 828.45 $207.11 $41.42
773-81 1977 776.75 0 38.84
21277-80 1978 2,212.43 0 110.62
All issues, except one, in these cases have been resolved by agreement of the parties and are included in their stipulation of facts. These agreed adjustments can be given effect in the computations to be submitted later under Rule 155,…
2Cases cited3 opinions
- Palmer v. CommissionerUnited States Tax Court · 1969
- Henson v. CommissionerUnited States Tax Court · 1976
- Varga v. United StatesDistrict Court, D. Maryland · 1979
3Cited by16 opinions
- Wingo v. CommissionerUnited States Tax Court · 1987
- Jack M. Ballinger and Brenda M. Ballinger v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1984
- Knight v. CommissionerUnited States Tax Court · 1989
- Peverill v. CommissionerUnited States Tax Court · 1986
- William C. Blakely and Bettie Blakely v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1983
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