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treatment of the income from CDI as passive, and, as a result,
disallowed the use of the passive losses from the partnerships to
offset petitioners' income from CDI.
In preparing for trial, petitioner recalculated the hours of
time he had spent on CDI activities. Petitioner used a somewhat
different process for trial than he did in 1990 and 1991 because
his "motivation is much different * * * I have to in part defend
myself * * * [and] have to be very accurate which I wasn't
advised of in 1990 and 1991". In his recalculation, petitioner
compiled a list of projects and activities that he was involved
with for CDI and broke each of them down into various parts.
Then, he examined all of the related documents in his possession
pertaining to such activities and assigned a time to each of the
activities based on his judgment and experience. Occasionally,
the time allocated to an activity was also set forth in the
calendar and could be cross-referenced for accuracy. Petitioner
did not use a cushion in making this calculation, and in this
manner he determined that he had spent 318.75 hours in 1990 and
439.8 hours in 1991 on CDI activities.
Among the numerous estimates made in his recalculation,
petitioner determined that he held informal office meetings for 4
hours and secretarial meetings for 2.5 hours. Some of the time
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