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All of my calls go in the "phone" context.

I think of my calls as being in one of two states: calls I can make now and calls I need to make later.

When I leave a message, the call becomes one I need to make later (if they don't call back), so I note that I've LMTC (left message to call) and set the start date for the item forward by when I expect them to call back.