William N. and Moira M. Carlstedt - Page 15

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            signing checks, such as engaging in travel and entertainment, and                            
            performing any other miscellaneous work for CDI such as                                      
            distributing tickets to CDI employees.  Moreover, he did not                                 
            include time that he spent proposing and negotiating build-to-                               
            suit leases for the partnerships from which CDI was certain to                               
            earn income constructing tenant finishes.  Nor did petitioner                                
            allocate to CDI any time that he spent on bid presentations for                              
            projects CDI did not obtain, as many records relating to such                                
            presentations were no longer available.  In at least one                                     
            instance, petitioner did not allocate to CDI any time spent in                               
            determining whether an invoice belonged to CDI or the                                        
            partnerships, even though ultimately he determined the expense                               
            was CDI's.  He claimed that this was because he was acting in his                            
            role as managing general partner to determine it was not a                                   
            partnership expense.                                                                         
                  Petitioner testified that he never had any confusion as to                             
            whether he was acting on behalf of CDI or the partnerships during                            
            1990 or 1991.  Petitioner admitted, however, that "we may not                                
            have been as careful on formality as we should have".  Moreover,                             
            his contractors and clients on occasion confused CDI with the                                
            partnerships in their correspondence.  Although certain letters                              
            were addressed to CDI, petitioner determined that they involved a                            









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