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HALL v. C.I.R.

No. 93-9027.

30 F.3d 1304 (1994)

James B. HALL, Nancy J. Hall, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

July 19, 1994.

Attorney(s) appearing for the Case

Garth J. Nicholls of Warren, Mundt & Martin, Colorado Springs, CO, for petitioners-appellants.

Loretta C. Argrett, Asst. Atty. Gen., Bruce R. Ellisen and Sara Ann Ketchum, Attys., Tax Div., U.S. Dept. of Justice, Washington, DC, for respondent-appellee.

Before LOGAN, SETH and BARRETT, Circuit Judges.

LOGAN, Circuit Judge.

Petitioners James B. Hall (hereinafter "taxpayer") and Nancy J. Hall1 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...

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