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pay this amount to MIT 80 in 1981, or in 1982, or in 1983. It
instead deferred payment of the compensation fee, thus becoming
subject to the 10-percent annual "late charge". On its books for
each of those years, Machise accrued and deducted for Federal
income tax purposes the late charges payable to MIT 80.
Throughout 1981 and 1982, investors in MIT 80 continued to
make monthly cash payments of interest and principal on their
notes to Intercoastal. By the end of March 1983, Dr. Crescenzo
had made 32 payments on his note to Intercoastal in the total
amount of $63,432. Of this amount, $26,727 was principal and
$36,705 was interest.8
Ingemi died early in 1983 and Bucci became owner of 100
percent of the stock of Intercoastal/Machise.
In the first few months of 1983, Dr. Crescenzo and the other
MIT 80 investors executed new notes, prepared by Fred, in favor
of Machise. These notes served as substitutes for the partners'
original $2.4 million notes to Intercoastal, which were canceled.
Some of the new notes were in reduced amounts, reflecting
investors' intervening payments to Intercoastal. Other notes
reflected increased amounts as a result of some investors'
increased obligations to BBPA, which had occasionally made
monthly payments to Intercoastal on behalf of those investors.
8In the aggregate, all the investors in MIT 80 paid cash of
$755,142, of which $310,672 was principal and $444,470 was
interest.
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