Barry B. Bealor and Nancy L. Bealor, et al. - Page 43

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          Investors in MIT 80                                                         
               There were nine investors who became partners in MIT 80--six           
          individuals, a trust, and two partnerships that BBPA had                    
          organized.  One of the individual partners was Donald P.                    
          Crescenzo (Dr. Crescenzo), a dentist who practices in Hammonton,            
          New Jersey.  The Bryens were his accountants.  Bruce recommended            
          that he invest in tax shelters.  He invested in MIT 80 because of           
          the tax-sheltered nature of the investment.  Dr. Crescenzo had a            
          lot of faith in the Bryens and left the matter of his investment            
          entirely up to Bruce.  He was later surprised to discover that,             
          in the course of becoming a partner in MIT 80, he had signed a              
          note for $150,000.                                                          
               The MIT 80 investors were provided with a three-page                   
          document prepared by BBPA that set forth projections of income              
          and expenses to the end of the partnership term.                            
          Organization and Management of MIT 80                                       
               Beginning in July 1980, the nine MIT 80 investors executed             
          powers of attorney in favor of BBPA.  Thereafter, at Fred's                 
          suggestion, Bruce signed the partnership agreement of MIT 80 on             
          behalf of its investors, who thereby became partners in MIT 80.             
               During July 1980, the investors, including petitioner                  
          Dr. Crescenzo, also executed promissory notes aggregating $2.4              
          million to Intercoastal.  The notes bore interest at the annual             
          rate of 10 percent on the unpaid principal.  The notes specified            






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