William N. and Moira M. Carlstedt - Page 26

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            for the partnerships.  Roger Eiteljorg stated that they met with                             
            only 1 or 2 potential lenders each week over the 2-year period.                              
            In addition, the development of information packages for                                     
            prospective lenders did not have to be done repeatedly; much                                 
            information compiled by petitioners appears to be of the type                                
            that could have been used over again before being tailored to the                            
            requirements of specific lenders.  Furthermore, although                                     
            petitioner and Roger Eiteljorg said that prospecting for tenants                             
            was one of petitioner's primary responsibilities as managing                                 
            general partner of the partnerships, that was also one of CMI's                              
            responsibilities.  No explanation was made as to why the                                     
            employees of CMI were not charged with this task, or why the time                            
            spent on that activity by petitioner was allocated to the                                    
            partnerships and not to CMI.                                                                 
                 We also do not find the testimony of petitioners' witnesses                            
            as to his participation in CDI persuasive, and there is little                               
            objective evidence in the record to support petitioner's self-                               
            serving estimations.  None of petitioners' witnesses could attest                            
            to the number of hours that petitioner spent working for CDI, and                            
            they only gave vague statements as to the extent of his                                      
            participation.  Petitioner himself stated that it was "difficult                             











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