- 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.Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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