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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,
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