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a sham, as respondent contends. That claim is pending in docket
No. 3221-93. Respondent has agreed that, in the event we so
determine, the requested reduction is appropriate.
None of the investors in W & A ever received any return from
their participation in W & A.
The Investors
In promoting the various partnership as tax shelters, Bruce
told the investors that the shelters were "set up on a cash
basis, there was a partnership and the loss would flow through to
them on their personal return." Bruce advised the investors that
an economic return on their investment could be paid quickly or
"it could be deferred for 10 years, and they would be paid right
after the beginning of the eleventh year, that it was up to the
payer, to the operating company."
One of the investors in MIT 82, as well as other of the MIT
shelters partnerships, was Anthony Schweiger (Schweiger).
Schweiger is a mortgage banker. He was aware that the
partnerships in which he invested were employee leasing
arrangements with 1-year terms. He was aware of no partnership
meetings, however, nor of any partnership votes.
Schweiger and the other investors received occasional
memoranda about developments during the year with respect to
their investments. A typical memorandum reads as follows:
TO: Mr. Anthony Schweiger
FROM: Bruce Bryen
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