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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 of
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