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Haskel Engineering & Supply Co., 380 F.2d 786, 788 (9th Cir.
1967). The focus must be, therefore, on the primary purpose of
the expenditure as it may be inferred from the totality of the
facts concerning the benefits to be achieved, the direct
relationship of those benefits to petitioner's business, and the
reasonableness of the expenses. Love Box Co. v. Commissioner,
T.C. Memo. 1985-13, affd. 842 F.2d 1213 (10th Cir. 1988).
Whether an expenditure is reasonable is a question of fact.
Commissioner v. Heininger, 320 U.S. 467, 475 (1943); Voigt v.
Commissioner, 74 T.C. 82, 89 (1980). In this case, petitioner
deducted over $2,300 in expenses relating to his participation in
the Big League Sales Course. The Big League Sales Course, while
promoted as a sales training course, involved little more than
petitioner's reading Dane's book. Although petitioner stated
that the "course" was not offered at any other location, it is
difficult to believe that petitioner could not have received the
same training from reading the Dane book in the comfort of his
home. The "examinations" by the course supervisor did nothing to
reinforce petitioner's learning. Furthermore, the location of
the course on Church of Scientology property, the restriction of
participation to Scientologists alone, and the apparent use of
Scientology scriptures as part of the "course" indicate that the
pervasive purpose of this course was not that of improving
petitioner's sales skills. The course cost and expenditures
associated with the course are not reasonable in light of the
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