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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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