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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 a
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