- 4 - Church of Scientology scriptures on consulting in addition to the Dane book. As part of his course of study, petitioner was to practice the sales techniques from his reading on other students. Because petitioner was the only person enrolled in the sales course at the time, however, this was not possible. After petitioner finished a reading assignment, a supervisor, who oversaw several of the Scientology course offerings, would "examine" petitioner about the portion of the book he had read. This examination consisted of petitioner's attesting to the completion of the materials. The supervisor would ask: "Can you apply those materials?" Petitioner would respond: "Yes, I can apply those materials." During 1976, petitioner was enrolled in other Church of Scientology courses. The other courses, however, related solely to spiritual counseling. On his 1976 Federal income tax return, petitioner deducted the $948 course fee and $1,366 in additional money spent on travel, accommodations, and other expenses relating to the course. Respondent disallowed the deduction. OPINION Petitioner bears the burden of establishing that he is entitled to the claimed deductions. Rule 142(a); INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); Rockwell v.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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