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the rent he paid on the Bridgeford property. Respondent
disallowed 60 percent of this deduction.
The Bridgeford property was a house containing three
bedrooms, two bathrooms, a family room/dining room, and a
kitchen. Petitioner placed freezers, where he stored his food
products, in the garage. Petitioner used only one or two rooms
of the house, in addition to the garage, for business purposes.
Petitioner traveled on business Monday through Friday.
Petitioner stayed overnight at the Bridgeford Drive property and
cooked meals there.
Petitioner enrolled in the Big League Sales Course in late
1976. The course was offered exclusively to Scientologists
through the Church of Scientology and took place on church-owned
property in Florida. The course was not offered in any other
location.
While in Florida, petitioner's accommodations were in the
Fort Harrison Hotel, which the Church of Scientology owned.
After approximately 20 days, petitioner completed the course and
received a certificate designating him a "Hubbard Professional
Service Consultant".
The course required petitioner to read assigned portions of
a 193-page book by Les Dane (Dane) entitled "Big League Sales
Closing Techniques". Petitioner had purchased and read the book
in its entirety in 1974 and read it again in relation to the
course taken in 1976. The Big League Sales Course also used
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