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of CDI, owned 20 percent of the stock. Petitioner was paid a
salary by CDI in 1990 and 1991 in the amounts of $93,885 and
$74,130, respectively.
CDI earned its gross income in 1990 and 1991 from two
sources. Approximately 93 to 95 percent of its income was
derived from commercial construction contracts obtained through a
competitive bidding process. CDI earned the remaining 5 to 7
percent of its income from the construction of leasehold
improvements (tenant finishes) for unrelated third parties, as
well as for tenants in buildings owned by Citimark.
In 1990 and 1991, petitioner engaged in a number of
activities on CDI's behalf. He met with CDI project managers
(Kenneth Johnson and John Cook) and superintendents and,
occasionally, with the company's estimators. Petitioner held
formal company meetings and field meetings concerning the general
business of CDI. He held secretary meetings and accounting staff
meetings. He met with CDI's bonding and insurance companies.
Petitioner also prepared for and made project presentations to
certain prospective customers. He occasionally discussed project
bid markups with Dickman. Petitioner made decisions regarding
the legal affairs of the company and met or spoke with CDI's
attorneys to discuss such matters. Petitioner also made
occasional site visitations in connection with projects under
construction.
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