- 10 - In an attempt to secure long-term financing, petitioner developed numerous information packages valuing the buildings for potential lenders. These packages also included background information about the partnerships. Petitioner, along with Roger Eiteljorg, contacted roughly 100 financial institutions each year on behalf of the partnerships in an attempt to find long-term financing. Many were contacted twice. Approximately 80 pension funds and 27 life insurance companies were also contacted in this manner. Petitioner's efforts to refinance the partnerships occupied much of his time, both in 1990 "and especially in '91". Petitioner's Estimations of Time Spent on CDI Activities in 1990 and 1991 In mid-1990, petitioner's accountant informed him of the possibility of offsetting his share of the partnerships' passive losses against his income from CDI if petitioner were to spend less than 500 hours on CDI activities for the year. The accountant advised petitioner to keep a reasonable record of his time, and to review his activities for the months in 1990 that had already passed. Petitioner maintained a contemporaneous calendar of a portion of his time and activities during the years in issue. For 1990, petitioner listed activities on his calendar related to CDI and the partnerships totaling 641 hours. Of that amount,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011