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PK Ventures, in 1987 to enable them to purchase Zephyr Rock &
Lime, Inc. (Zephyr), was a bona fide loan and, if so, whether
that debt ever became worthless (Issue #1);
(2) whether transfers of funds from PK Ventures and/or its
subsidiaries to PKVI LP prior to and during 1990 and during 1991
were bona fide loans and, if so, whether such debts ever became
worthless (Issue #2);
(3) whether transfers of funds from PK Ventures and two of
its subsidiaries to Zephyr prior to 1990 were bona fide loans
and, if so, whether such debts ever became worthless (Issue #3);
(4) whether PK Ventures had sufficient basis in its PKVI LP
interest during 1990, 1991, 1992, and 1993 to deduct the losses
that it claimed from PKVI LP on PKV&S’s consolidated Federal
income tax returns for those years (Issue #4);
(5) whether the Roses had sufficient basis in their PKVI LP
interest during 1990, 1991, 1992, 1993, 1994, and 1995 to deduct
the losses that they claimed from PKVI LP on their joint Federal
income tax returns for those years (Issue #5);
(6) whether the Roses had sufficient basis in their Zephyr
interest during 1990, 1991, and 1992 to deduct the losses that
they claimed from that S corporation on their joint Federal
income tax returns for those years (Issue #6);
(7) whether the Roses had sufficient basis in their
St. Louis Pipeline Corp. interest during 1994 and 1995 to deduct
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Last modified: May 25, 2011