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MIT 82
Formation of MIT 82
On January 1, 1982, Fred and Bruce organized and promoted
MIT 82, in the form of a general partnership.10 As with MIT 80,
MIT 82's address was the same as BBPA's. MIT 82 used the
calendar year as its tax year and the cash method of accounting
from its inception through December 31, 1986. BBPA made the
general journal entries for MIT 82 for the years 1982 through
1986 and adjusting journal entries for 1982 through 1987.
Like MIT 80 before it, MIT 82 entered into an employee
leasing agreement with Machise under which MIT 82 was to provide
all the individual employees and independent contractors required
by Machise for the period January 1 through December 31, 1982.
The arrangement was essentially the same as that of MIT 80, but
this time BBPA paid more attention to details. The employee
leasing agreement again stated that the partnerships would
provide Machise with employees, independent contractors, and
equipment, plus biographical information about those workers. It
also provided that the partnership would have the right to
control and direct the employees and that the partnership would
10Fred had also organized MIT 81 to lease employees and
independent contractors to Machise for the period Jan. 1 through
Dec. 31, 1981. There are no cases before this Court involving
adjustments to the partnership returns of MIT 81 or to the tax
returns of the individual participants in MIT 81 with respect to
their interests in MIT 81.
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