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read many of the carbon copies frequently sent to him by his
employees, even though he was CDI's president. Even more
problematic is the fact that some times were not assigned at all
to activities he engaged in CDI, such as bid presentations on
projects CDI did not get, since documents for such presentations
were not always available.
Petitioner claims that he did not spend much time on CDI
activity because his partnerships, together with various civic
and familial responsibilities, preoccupied him during the years
at issue. While petitioner's participation in activities other
than CDI may have had a bearing on the level of his activity for
CDI, that does not necessarily mean his participation in CDI
dipped below 500 hours. In this regard, we note petitioner's
testimony that "especially in 1991" the time he spent on the
partnerships had increased, yet by his own estimate, his time at
CDI had increased substantially that year as well. Thus, time
spent on the two activities by petitioner was not inversely
proportional.
In addition, petitioner's partnership activities do not seem
as onerous as he claimed. Roger Eiteljorg was available to
assist petitioner in his efforts to secure long-term financing
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