James A. and Joan H. Soholt - Page 3




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          other court, and the opinion shall not be treated as precedent              
          for any other case.                                                         
               Respondent determined a $3,360 deficiency in petitioners’              
          Federal income tax for 2003.  After concessions,2 we are asked to           
          decide whether petitioners are entitled to deductions for various           
          expenses.  We find that petitioners are entitled to deduct some             
          of the expenses they claimed on their returns.                              
                                     Background                                       
               Some of the facts have been stipulated and are so found.               
          Petitioners resided in Minneapolis, Minnesota, at the time they             
          filed the petition.                                                         
          Mr. Soholt’s Business Activities                                            
               Petitioner Mr. Soholt was a financial adviser and retirement           
          planner for Metropolitan Life Insurance Company (MetLife) in                
          2003.  He provided financial advisory services and products to              
          various clients and groups.  Mr. Soholt used his car to meet with           
          clients and prospective clients at locations convenient to them.            
          Sometimes he would take clients or prospective clients out for              
          coffee or a light meal or snack.                                            
               Mr. Soholt worked from a home office set up in the basement            
          that constituted approximately 18 percent of petitioners’ home              


               2Petitioners concede that they are not entitled to deduct a            
          portion of their personal property taxes and that they are not              
          entitled to deduct expenses for professional publications.                  
          Respondent concedes that petitioners are entitled to deduct their           
          expenses for continuing education and licensing.                            





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