Barry B. Bealor and Nancy L. Bealor, et al. - Page 83

                                       - 31 -                                         
                                       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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