James B. Hall, Nancy J. Hall v. Commissioner of Internal Revenue

LOGAN, Circuit Judge.

Petitioners James B. Hall (hereinafter “taxpayer”) and Nancy J. Hall 1 appeal the Tax Court’s decision that taxpayer’s application as a minister for an exemption from self-employment tax pursuant to Internal Revenue Code (I.R.C.) § 1402(e), 26 U.S.C. § 1402(e), was untimely. We review the Tax Court’s conclusions of law de novo and its findings of fact for clear error. Resale Mobile Homes, Inc. v. Commissioner, 965 F.2d 818, 821 (10th Cir.), cert. denied, — U.S. -, 113 S.Ct. 212, 121 L.Ed.2d 151 (1992). 2

Taxpayer was ordained as a deacon in the United Methodist Church in…