Barry B. Bealor and Nancy L. Bealor, et al. - Page 125

                                       - 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 to                 




Page:  Previous  63  64  65  66  67  68  69  70  71  72  73  74  75  76  77  78  79  80  81  82  Next

Last modified: May 25, 2011