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These findings are necessary for an understanding of the issues
presented. The descriptions of the transactions, however, are
not meant to indicate that the events described actually
happened, or that they had any economic effect. We reserve for
the opinion below our discussion and conclusions on those
matters.
MIT 80
Formation of MIT 80
Fred decided to abandon the MIT Personnel/Machise leasing
arrangement in order to promote annual tax-shelter partnerships
that would utilize Machise. To this end, in 1980, Fred and Bruce
organized and promoted a general partnership named MIT 80. MIT
80's business address was Allison Drive, Cherry Hill, New Jersey,
the same address as BBPA’s. MIT 80 moved its business address to
100A Centre Boulevard, Marlton, New Jersey, when BBPA moved
there. MIT 80 used the calendar year as it tax year. In order
to carry out its tax-shelter objectives, MIT 80 employed the cash
method of accounting until December 31, 1986, when it was
required to change to the accrual method in accordance with a
change in the accounting provisions of the Internal Revenue Code.
MIT 80 obtained an employer identification number from the
Internal Revenue Service and opened a payroll account at the
Guarantee Bank. Bucci and Ingemi were signatories on this
account.
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