- 39 - unpaid portions of the compensation fee. Thus, Machise was not required to, and did not, make any payment of the "compensation fee" to MIT 82 during 1982. MIT 82, under its cash method of accounting, accordingly reported a net loss of $2,488,164. This loss was the excess of the $2,504,865 payroll costs and other expenses over reported partnership interest income of $16,701. Individual Petitioners' Deductions of Partnership Loss On their individual income tax return for 1982, the Bealors reported a loss of $80,915, representing their 3.252-percent share of MIT 82's partnership loss. James Cameron reported the same amount as his 3.252-percent share of those losses in his 1982 Federal income tax return. Frank Pettisani, in his 1983 return, reported a Schedule E loss of $161,830, representing his 6.504-percent share of MIT 82 losses. The other investors in MIT 82 also reported Schedule E partnership losses from MIT 82, in proportion to their interests. Respondent issued statutory notices of deficiency to the named investors and the other investors, disallowing the claimed MIT 82 losses for 1982. Intercoastal's Deduction of Compensation Fee For the 6-month period January 1, 1982, to the end of its fiscal year on June 30, 1982, Machise/Intercoastal accrued and deducted, as "rents" for Federal income tax purposes, $1,389,950 with respect to payroll costs. For the next 6-month period ofPage: Previous 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 Next
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