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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.
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