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Schweiger's primary consideration in participating in the
MIT partnerships was to obtain tax benefits. He had previously
invested in three other tax shelters promoted by Fred and Bruce
through BBPA. Schweiger identified one of these shelters as "P&G
which was the school bus operation, Pat & Gordon".
Charles Thompson (Thompson) was another investor in the MIT
shelters. He was told that his taxes would be reduced, but he
does not recall any representation being made about investment
profits. He recalls no partnership meeting nor partnership
votes. He was not aware that he was a general partner in the
partnerships. He did not understand how his notes were paid off,
nor did he receive news of the termination of the employee
leasing arrangement.
Thompson did not have regular meetings with the accountants
at BBPA; he only went to them with his tax materials for purposes
of preparing his income tax returns.
Another of the investors in W & A was Alexander M. Churchill
(Churchill), a civil engineer. BBPA was the accountant for
Churchill's engineering business, and Churchill’s tax preparer.
Churchill saw Bruce two or three times a year, with respect to
Churchill's individual tax matters. Bruce had induced him to
invest in W & A, as well as other earlier tax shelters.
Churchill participated for "investment purposes and also to
shelter some of my income." In addition to the MIT tax shelter
partnerships, the Bryens also brought other tax shelters to
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