- 38 -
filed.
MIT 82 paid $1,947,852 to employees and independent
contractors and taxing authorities. Some $51,908 was paid or
accrued for workmen's compensation, health, and group life
insurance premiums. MIT 82 paid an additional $461,092 for
professional and management fees and $106 for bank charges. Of
this amount, some $460,000 constituted fees paid to Intercoastal
for the management of Machise. MIT 82 also accrued a pension
contribution expense of $43,907.13 The total was $2,504,865.
As with MIT 80, the employee leasing agreement required
Machise to pay to MIT 82 a "compensation fee" of 115 percent of
the payroll costs paid by MIT 82, plus 115 percent of the amount
MIT 82 paid to Intercoastal for management services. Under the
employee leasing agreement, no part of this compensation fee was
due and payable until June 30, 1983, 6 months after MIT 82's
obligation to furnish employees and independent contractors had
ceased. Machise could also defer payment of the compensation fee
for more than 10 years, until July 1, 1993, if it paid a 10-
percent per year late charge from June 30, 1983, on all deferred
13The exhibits include a "Valuation Report" of the "M.I.T.
82 Money Purchase Pension Plan" prepared by an independent
pension-administration company. This report contains, as an
attachment, a Form 5500-R "Registration Statement of Employee
Benefit Plan". That form indicates that the plan sponsor was MIT
Personnel Co. and that the plan was instituted on Dec. 31, 1973.
The form, which bears the date 1982, also indicates that the plan
was not "terminated during this plan year or any prior plan
year." As with the other partnerships, MIT 82 was a party
apparently only by virtue of a "participation agreement" with the
MIT Personnel Co. plan. See supra note 5.
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