- 7 - 1987 840,838 1988 969,316 1989 1,335,995 3461-92 MIT 84 1986 546,300 1987 1,315,352 1988 23,889 1989 1,423,786 3462-92 MIT 86 1987 4,855,505 3551-92 MIT 83 1987 797,976 1988 360,236 1989 1,218,735 3221-93 W & A 1988 3,586,156 The cases in the foregoing dockets have been selected by the parties as test cases that will resolve common issues in more than 120 cases in a group identified by respondent as "Fred Bryen Promotions". Most petitioners in the nontest cases have executed "piggyback agreements" in which they agree with respondent to be bound by the outcomes in the test cases. Issues The global issue in these consolidated cases is the tax effect of the purported employee leasing transactions of seven partnerships. By agreement of the parties, the questions presented for decision are whether the transactions of the seven partnerships had (1) economic substance and (2) a profit objective. Because we answer those questions in the negative, we hold that neither the partners nor the partnerships are entitled to loss deductions for payroll costs, that the Pettisani petitioners are not entitled to deductions for interest on certain long-term notes, that petitioner Intercoastal ManagementPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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