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Petitioners, husband and wife, who resided in Roseville,
Minnesota, at the time of the filing of their petition in this
case, filed their joint Federal income tax return for the
calendar year 1987 with the Andover Internal Revenue Service
Center, and filed their joint Federal income tax return for the
calendar year 1988 with the Kansas City Internal Revenue Service
Center.
During the years 1987 and 1988, Sherman J. Miller
(petitioner) was employed as a full-time school teacher in the
St. Paul, Minnesota, area. During these years, petitioner was
also self-employed selling insurance. He was licensed to sell
insurance in both Wisconsin and Minnesota. Petitioner conducted
his insurance business in the St. Paul area out of his home in
Roseville, Minnesota.
During the years at issue, petitioner made trips in the
summer months to the Hayward, Wisconsin, area. Hayward is a
recreational area located approximately 160 miles northeast of
St. Paul, which attracts people from Wisconsin, Minnesota, Ohio,
and Illinois. Petitioner spent approximately 35 days in Hayward
during the summer months of each of the years 1987 and 1988.
Petitioner usually spent 2 days in Hayward on each trip.
Petitioner solicited clients and potential clients for his
insurance business in the St. Paul, Minnesota, area through both
direct mail and by field work, which he referred to as
"prospecting". Petitioner's insurance-related activity in
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