James Pullano is a partner with Partnership V, a hardware store, in which he spent 465 hours in the tax year working. He also worked 165 hours with Partnership W, an architecture partnership that designs and builds backyard gazebos, as the primary builder. Finally, he spent 195 hours launching Partnership AB, a new business building bandstands for concerts. None of the entities are publicly traded. He is considered a(n) _______________ for tax purposes