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Ah, now I understand! You want to make a nested context on the spot to finish the new action you are creating. I filed a bug report about the inability to do that back in May (ticket #437942) but it has not been fixed yet so far as I can tell.

On the desktop, you can do so in the outline by typing ":subcontext" after your parent context and then cmd-return. I think it should work the same way on the iPhone, but what you end up with is a top-level context named "parent:subcontext" instead. Send in your bug report (with a reference to my ticket number, too) and maybe the sudden surge of interest in this feature will convince them to act :)