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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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Last modified: May 25, 2011