Barry B. Bealor and Nancy L. Bealor, et al. - Page 68

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               as may be mutually agreed between the Partnership and                  
               the Company * * *.                                                     
                     *      *      *      *      *      *      *                      
                    (d)  The Partnership shall have the exclusive                     
               right to determine the contractor to be used to fulfill                
               the Partnership's obligations under this Agreement.                    
               Fred provided that the term of the employee leasing                    
          agreement between MIT 80 and Machise would be for 1 year so that,           
          in each succeeding year, he could bring in more investors who               
          would be able to deduct their shares of the first-year loss of a            
          new and different tax shelter partnership.  Bruce signed the                
          employee leasing agreement on behalf of the partners in MIT 80,             
          writing the words "by power of attorney" below each signature.              
               Journal entries indicate that MIT 80 advanced 100 percent of           
          its $2.4 million capital to Intercoastal on July 29, 1980,                  
          although MIT 80 was not specifically required to do so by the               
          employee leasing agreement.  The journal entries reflect that               
          these advances took the form of MIT 80's further endorsement of             
          $2.4 million in checks that originally had been drawn by                    
          Intercoastal, made payable to the MIT 80 investors, and deemed to           
          have been used by them as their initial investment in MIT 80.               
          However, the journal entries are the only documents indicating              
          the endorsements; MIT 80 did not in fact endorse these checks to            
          Intercoastal.  None of the checks entered banking channels;                 
          instead, as Fred intended, they circled back to Intercoastal,               
          their drawer.                                                               





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