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based on square footage. MetLife leased him a laptop computer
through which he could connect to the MetLife network from home.
The home office also included a desk, filing cabinets, and
storage space for marketing and informational materials.
Although Mr. Soholt kept a few de minimis personal papers in the
filing cabinets, the family living area was located on another
floor of the home, and the home office was not used for family
activities. Mr. Soholt insured the home office (including its
materials and equipment) against flood and other catastrophes.
Petitioners installed a second telephone line to the house for
Mr. Soholt to use for business. Mr. Soholt used calling cards to
dial clients long distance. He also had a cellular phone.
Petitioners subscribed to the Sunday Star Tribune. Mr.
Soholt read the business section each week to learn about
business news in the area and to be prepared in case a client
asked him a question about a particular news story. Both
petitioners read other sections of the newspaper for personal
reasons.
Mrs. Soholt’s Business Activities
Petitioner Mrs. Soholt was a flight attendant for Northwest
Airlines (NWA) during 2003. She was on sporadic leave from
January through May, however. The sporadic leave program,
instituted during the airline’s economic crisis brought on by the
2001 terrorist attacks, allowed NWA employees to take time off
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