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THE COURT: I mean, let’s put it this way,
anything you get involved in, becomes part of your
ministry. Is that what you're telling us?
PETITIONER: Well, if I sign up for a multi-level
marketing situation, then that’s part of what I am
using in the overall picture to help people to make
money.
C. Recordkeeping
Petitioner did not maintain a separate bank account for his
“health, wealth and healing ministry” activity. Rather, he
maintained a single checking account for all of his affairs.
Of the hundreds of checks that he wrote during the years in
issue, petitioner categorized the vast majority, including all of
the checks written to grocery stores, as “unreimbursed employee
expenses”. Indeed, petitioner categorized only a couple of
checks (in the aggregate amount of $40) as “household expenses”.
In this regard, petitioner testified at trial that he lived with
his mother who paid most, if not all, of his personal living
expenses. Thus, for example, petitioner testified: “I
wasn’t buying any of the food. My mother was buying it all.”
and that “I didn’t do any of my own shopping.”
D. Financial Track Record of Petitioner’s Activity
As of the date of trial, petitioner had yet to make a profit
in his “health, wealth and healing ministry” activity.
E. Petitioner’s 1996 Income Tax Return
Petitioner filed a Format U.S. Individual Income Tax Return,
Form 1040PC, for 1996, listing his occupation as “healing
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