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MIT 83
The organization and operation of MIT 83 resembled those of
MIT 82. However, the program was further complicated by the
addition of other entities.
On January 1, 1983, Fred and Bruce organized and promoted
MIT 83 as a general partnership. Like MIT 80 and MIT 82, MIT 83
used the calendar year as its tax year and the cash method of
accounting from its inception until December 31, 1986. As with
MIT 80 and MIT 82, its address was the same as BBPA's. BBPA made
the journal entries of MIT 83 for 1983 and 1984 and its adjusting
journal entries for 1984, 1985, 1987, and 1988.
As with MIT 80 and MIT 82, MIT 83 had a bank account at the
Guarantee Bank, which was the payroll account. Pursuant to
authorization by BBPA, Bucci was an authorized signatory on the
MIT 83 account.
MIT 83 Investors
Fred prepared the MIT 83 partnership agreement. There were
25 partners, 23 individuals and 2 partnerships. Some of the
prospective investors in MIT 83 received a three-page document
prepared by BBPA. It set forth projections of financial income,
expense, and cash-flow to the end of the partnership term.
Organization and Management of MIT 83
A corporation named Qulart, Inc. (Qulart), had been formed
on December 4, 1979, with Bruce as its sole shareholder. Qulart
used a fiscal year ending June 30 as its tax year and employed
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