- 15 - signing checks, such as engaging in travel and entertainment, and performing any other miscellaneous work for CDI such as distributing tickets to CDI employees. Moreover, he did not include time that he spent proposing and negotiating build-to- suit leases for the partnerships from which CDI was certain to earn income constructing tenant finishes. Nor did petitioner allocate to CDI any time that he spent on bid presentations for projects CDI did not obtain, as many records relating to such presentations were no longer available. In at least one instance, petitioner did not allocate to CDI any time spent in determining whether an invoice belonged to CDI or the partnerships, even though ultimately he determined the expense was CDI's. He claimed that this was because he was acting in his role as managing general partner to determine it was not a partnership expense. Petitioner testified that he never had any confusion as to whether he was acting on behalf of CDI or the partnerships during 1990 or 1991. Petitioner admitted, however, that "we may not have been as careful on formality as we should have". Moreover, his contractors and clients on occasion confused CDI with the partnerships in their correspondence. Although certain letters were addressed to CDI, petitioner determined that they involved aPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011