- 73 - which it called compensation fee income, and no expenses. In 1987, MPC issued a similar note, which circled through the partners, the partnership, and Qulart, and back to MPC. MIT 85 reported partnership taxable income of $1,865,187 on its partnership return for 1987. This amount consisted of $1,571,520 (one-half of the $3,143,039 deferred income that it was allocating over 2 years due to the change in accounting method), plus $293,667, which it called fee income, and which represented the accrual of interest payable from MPC, and no expenses. On January 1, 1988, Fred prepared a Termination Agreement to end the obligations of MIT 85 and MPC under the employee leasing agreement. Under the terms of the employee leasing agreement, MPC owed $3,023,984 to MIT 85. MPC offered to pay $2,116,938 by transferring to MIT 85 the $2,160,000 note made by Qulart to Machise, now held by MPC, with a balance, including accrued interest, of $2,116,938. The Termination Agreement recited that, after assignment of the note, the balance due to MIT 85 was $907,045.98, but that MIT 85 had agreed to reduce that amount by $151,531.98 and to cancel the 10-percent annual late charge. Fred calculated the net amount due to MIT 85, some $755,514, so that it would equal the amount that he had projected as the aggregate income to the MIT 85 investors. Additionally, under the Termination Agreement, MIT 85 was required to distribute the note to its partners who were toPage: Previous 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 Next
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