Sherman J. Miller and Alice K. Miller - Page 3

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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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