Barry B. Bealor and Nancy L. Bealor, et al. - Page 96

                                       - 44 -                                         
          Machise but subsequently assigned to MPC.  There is no evidence             
          that MPC issued any note for $1,974,901.  A summary of the effect           
          of the MIT 82 Termination Agreement shows the following:                    
          Owed by MPC to MIT 82 as unpaid                $2,307,059                   
          compensation fee                                                            
          Accepted by MIT 80 in full satisfaction of     (1,974,901)                  
          amounts owed by MPC; this amount to be                                      
          used to offset Partners' notes to Machise                                   
          Amount forgone by MIT 82 in unpaid                332,158                   
          compensation fees                                                           
                                                                                     
               Fred designed the Termination Agreement so that everything             
          would "zero out".  He signed it under the heading "Bryen & Bryen,           
          P.A." on behalf of both MIT 82 and MPC.  Fred explained "the                
          whole reason they [the MIT 82 partners] did it is to get rid of             
          the risk.  They owed $2 million and if Machise [sic, read "MPC"]            
          did not pay the compensation fee, these partners would be after             
          me with guns."                                                              
          Partnership Income of MIT 82                                                
              For the year 1986, MIT 82 reported partnership taxable                 
          income of $428,142.  This amount included the $473,458 payment,             
          in the form of a Machise demand note, of compensation fee income,           
          plus interest from BBPA of $30,669, less $75,985 in accounting              
          fees and management expenses to BBPA.                                       
               For the year 1987, MIT 82, like MIT 80, changed its method             
          of accounting from the cash method to the accrual method,                   
          reflecting the new requirements of the Tax Reform Act of 1986.              
          MIT 82 accordingly reported partnership taxable income of                   
          $840,069 for 1987.  This consisted of $637,316, one-fourth of the           




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