- 5 - Penalty Year Deficiency Sec. 6662(a) 1990 $211,278 $2,269 1991 791,480 9,517 1992 649,700 1,316 1993 750,743 –- By Notice of Final Partnership Administrative Adjustment (FPAA) dated January 11, 1999, respondent determined an upward adjustment of $100,661 with respect to the ordinary income of P.K. Ventures I Limited Partnership (PKVI LP) for 1991. Robert L. Rose (Rose), the designated tax matters partner for PKVI LP, filed a Petition for Readjustment of Partnership Items Under Code Section 6226. Respondent determined deficiencies, an addition to tax, and penalties with respect to the Federal income taxes for petitioners Robert L. and Alice N. Rose (the Roses) for 1990, 1991, 1992, 1993, 1994, and 1995 as follows: Addition to Tax Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1990 $11,729 –- $2,346 1991 90,133 -- 18,027 1992 503,928 -- 100,786 1993 177,286 -- 35,457 1994 248,981 -- –- 1995 397,096 $8,446 -- The principal issues tried and briefed in these consolidated cases were: (1) Whether a transfer of $1 million from PK Ventures, Inc. (PK Ventures), to 10 individuals, 9 of whom were shareholders ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011