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Church headquarters is located in Nashville, Tennessee.
Subsequently, petitioner was licensed as a minister by the
Alabama District of the Council of the Assemblies of God of
Montgomery, Alabama. Petitioner is qualified to perform
sacraments, to baptize or christen, and to officiate at marriage
ceremonies and burials.
Petitioners believe that they were "called" to Dothan,
Alabama, to act in their capacity as Christian or pastoral
counselors. Accordingly, sometime in 1987, petitioners moved to
Dothan, Alabama, and established the Body of Christ Church of
Dothan, Alabama.3 Petitioners rented residences temporarily
while looking for a permanent residence and an office location.
Petitioners ultimately purchased a permanent residence in the
name of the Body of Christ Church of Dothan, Alabama.
Petitioners actually made the mortgage payments on the residence
and deducted the mortgage interest on Schedule C of their
individual income tax returns for the taxable years in issue.
Sometime in 1987 petitioners rented an office in downtown
Dothan, Alabama (the "downtown office") for the counseling
business. The downtown office rented by petitioners consists of
a counseling office, waiting room, reception area, and a bathroom
for the clients. Petitioners believe that any item that makes a
3 At the time of the trial, the Body of Christ Church of
Dothan, Alabama, consisted only of petitioners and was not an
incorporated entity.
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