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* * * to tell who worked for who" at the office. Dickman stated
that petitioner's hours at CDI "couldn't be very many". Mike
Price's testimony that petitioner spent "all his time with the
partnerships" is obviously not true since, by petitioner's own
admission, he spent several hundred hours a year on CDI business.
Kenneth Johnson merely stated that petitioner spent "the majority
of his time with the partnerships". However, he did not observe
petitioner's activities on a daily basis, and did not know the
level of petitioner's participation in CDI at the office or on
John Cook's projects. Cf. Harrison v. Commissioner, T.C. Memo.
1996-509 ("Although this Court has not always accepted a post-
event narrative of participation, * * * we find petitioner's
description of his participation, when combined with * * *
[witness] testimony and the objective evidence in the record, to
be credible".)
Finally, petitioner allocated no time to Mrs. Carlstedt's
activities for CDI, other than check signing. Mrs. Carlstedt was
partially responsible for ticket distribution to CDI employees.
Moreover, she attended events which, viewed objectively, could be
construed as having business development purpose. (Petitioners'
supplemental protest acknowledged as much.) Mrs. Carlstedt was,
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