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(general manager) who was to be directly responsible for planning
and implementing its objective of opening three additional
restaurants. During 1995, $180,000 was made available to the
general manager in order to enable him to accomplish that
objective. Through the efforts of the general manager, sometime
during 1995, a new corporation was organized,8 which opened and
operated a fast food restaurant in Beaverton. Because the
general manager exhausted the entire $180,000 that had been made
available to him in order to open only one restaurant in 1995,
his services were terminated around March 15, 1995.
Petitioner did not keep a contemporaneous log of any
activities that he undertook with respect to the Chicken Bar
business. At a time or times not disclosed by credible evidence
in the record, petitioner prepared a handwritten document
entitled “1995 - CHICKEN BAR LOG BOOK OF TIME SPENT ON CHICKEN
BAR BUSINESS” (1995 document). The 1995 document contains a
series of entries9 consisting of (1) very brief summaries of
certain activities that petitioner claims he undertook with
respect to the Chicken Bar business, (2) the respective dates
on which petitioner claims he undertook those activities, and
(3) the number of hours that he claims he spent on each such
8The record does not disclose the identities of the
stockholders, the officers, and other employees of the
corporation organized in 1995.
9The 1995 document contains 151 entries.
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