- 60 - agreement with MPC so as to avoid the risk of being required to pay their notes without MPC paying the partners themselves. Fred intended that all the parties to the MIT 83 employee leasing transactions would be "zeroed out" (with no further liabilities) following the purported termination. In addition, Fred never considered having Bucci obtain any legal representation or independent advice other than Fred himself concerning the alleged termination. MIT 83 Income On its partnership returns for 1985 and 1986, MIT 83 reported partnership taxable income of $519,960. On its partnership return for 1987, MIT 83 reported partnership taxable income of $797,976. This amount included one-fourth of the $2,437,470 deferred income that MIT 83 allocated over 4 years due to the change in accounting method imposed by section 448. To this amount was added “fee income” of $231,253. This fee income included accrued interest payable from MPC and an item of “portfolio income” in the amount of $42,645. The partnership’s taxable income further reflects a deduction of management fees payable to BBPA in the amount of $42,645--the same amount as the “portfolio income”. On its partnership return for 1988, MIT 83 reported partnership taxable income of $360,236; this amount included one- fourth of the $2,437,470 deferred income that it allocated over 4 years due to the change in accounting method, less $235,627,Page: Previous 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 Next
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