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(1) Marketing activities relating to a book that he authored and
published in a previous year; and (2) private educational
seminars that he conducted that were not connected with his
employment at Sierra.
Prior to 1992, petitioner wrote and published a book, at his
own expense. On January 6, 1992, petitioner paid a publishing
company $3,070.50 to have 1,035 copies of his book printed.
Petitioner was charged $3.003 per copy for the first 1,000 copies
and $2.250 for the next 30 copies. He received 5 free copies.
During 1992, petitioners traveled to several cities,
including the following: Phoenix, Arizona; Minneapolis,
Minnesota; Reserve, New Mexico; and Los Angeles, California.
Typically, there were large shopping malls in these cities and
located in these malls were retail bookstores. Without making
any advance arrangements or appointments, petitioner visited
several of the bookstores in the city where he happened to be in
an attempt to market his book. Usually he left a sample copy of
the book with the manager or other employee of the bookstore.
Petitioner did not maintain a log or other record to indicate
what bookstores he visited or the number of sample copies of his
book that he gave out during 1992. During these trips
petitioners visited with relatives who were living in the area.
In October of 1992, petitioner sold $124 worth of books. He
included this amount in the amount of gross receipts he reported
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