- 92 - Churchill's attention. Bruce did not explain to Churchill the significance of being a general partner in the MIT partnerships. Churchill knew of no partnership meetings, nor was he consulted on partnership operations. He did not know the other partners. He did not understand the accounting mechanisms of the partnerships, but he relied upon Bruce. Asked specifically about his participation in MIT 82, Churchill did not recall being consulted before termination of that partnership’s employee leasing agreement. Before trial in these cases, Fred informed the investors in writing that the trial was in the offing. A typical letter from Fred to an investor advises-- If you are called as a witness, Steve Jozwiak will prepare you for trial. In general, he will tell you to tell the truth and try not to become confused. Steve will expect you to testify to the true facts that you knew that you were at risk for $137,500.00 and that you expected to earn 13% on your investment which would be more than enough to pay your note. In addition you had the protection of your tax savings but you knew that you would have to pay taxes on the income that you would be reporting over the 10 year period. Steve will also expect you to testify that you expected Bryen & Bryen P.A. to manage your investment and MIT 82 and to take care of all of the details without consulting you. OPINION Three aspects of the employee leasing programs structured by Fred Bryen are in issue in these consolidated test cases. Respondent’s first set of determinations denies, for the years 1980 and 1982, to the partners, and in subsequent years (1983,Page: Previous 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 Next
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