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179.5 hours related to activities that petitioner determined
involved CDI and 461.5 hours related to activities that
petitioner determined involved the partnerships. In 1991,
petitioner's calendar listed activities related to CDI and the
partnerships totaling 620 hours. Of that amount, 257 hours
related to activities that petitioner determined involved CDI and
363 hours related to activities involving the partnerships.
At the end of each year, petitioner also summarized the
available records of his time into a so-called diary of
activities (the diaries). Petitioner's diaries were based on a
40-hour week, although petitioner acknowledged that he generally
had worked more hours than that per week. In preparing the
diaries, petitioner calculated the total number of hours he had
spent on CDI and his other enterprises. In so doing, he used his
calendar to remind him of the occurrence and length of meetings,
reviews, trips, as well as any site visits. He then examined
other available documents to provide allowances for phone calls,
travel and entertainment, and activities not otherwise listed on
his calendar. Petitioner testified that he included a "cushion"
of 30-40 hours of additional time worked for CDI each year in
case he forgot something. In this manner, he came up with the
following summary of hours for 1990 and 1991:
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