Barry B. Bealor and Nancy L. Bealor, et al. - Page 9

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          Background                                                                  
               The individual petitioners were residents of New Jersey                
          when they filed their petitions.  The principal place of business           
          of the partnerships known as MIT 80, MIT 82, MIT 83, MIT 84, MIT            
          85, MIT 86, and W & A Payroll Service was Marlton, New Jersey,              
          when their tax matters partner filed the petitions relating to              
          the administrative adjustments or requests for adjustments at               
          issue.  When petitioner Intercoastal Management Co. filed its               
          petitions, its principal place of business was Hammonton, New               
          Jersey.                                                                     
               Fred Bryen (Fred) has been a certified public accountant for           
          approximately 40 years.  From 1965 to 1978, he was a professor of           
          accounting at Rutgers University.  He is also one of the owners             
          and employees of the accounting firm Bryen & Bryen, P.A. (BBPA).            
          His son Bruce, also a certified public accountant, is also an               
          employee-owner of BBPA.  Marion Hunt, also a certified public               
          accountant, is the third owner-employee of BBPA.  BBPA provided             
          business and tax advice to clients and prepared tax returns, but            
          did not certify financial statements.                                       
               In the mid-1970's, Fred and Bruce began to structure and               
          promote tax shelters.  These tax shelters were structured by Fred           
          and primarily promoted by Bruce.                                            
               One of BBPA's accounting clients was Machise Interstate                
          Transportation Co., Inc. (Machise), a New Jersey corporation                






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