Thomas D. Stricker - Page 4

                                        - 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

Last modified: May 25, 2011