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Petitioner was in charge of hiring, firing, and evaluating
key personnel. He reviewed and signed contracts for construction
jobs and handled any miscellaneous nonrecurring matters related
thereto. Petitioner reviewed company correspondence and made
phone calls relating to the business of CDI. He also handled
miscellaneous administrative office matters, such as purchasing
athletic equipment and office furniture for the company.
Petitioner signed checks for CDI and engaged in entertainment and
other activities related to business development. In addition to
the above, in 1991 petitioner was also involved in insurance
claim matters and tenant finishes.
Although nominally an employee of CMI, Mrs. Carlstedt also
participated in activities on CDI's behalf. In 1990, Mrs.
Carlstedt submitted reports for reimbursement of expenses for a
number of different items of travel and/or entertainment incurred
for CDI. In addition, Mrs. Carlstedt was partially responsible
for distributing to employees of CDI tickets purchased by CDI to
Indianapolis Colts and Pacers games, Indianapolis 500 Festival
activities and other entertainment activities.
The Citimark Partnerships
Petitioner was also involved in the real estate development
business in 1990 and 1991. In the mid-1980's, CDI had
constructed 10 buildings on two parcels of land (Allison Pointe
and Castleton Business Park) located in northeast Indianapolis.
Each of the 10 buildings was owned by a separate partnership in
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