- 7 -
the losses that they claimed from that S corporation on their
joint Federal income tax returns for those years (Issue #7);
(8) whether the compensation that Rose received from PKV&S
during 1992 and 1993 was reasonable (Issue #8); and
(9) whether the Roses are liable for accuracy-related
penalties under section 6662(a) for 1990, 1991, 1992, and 1993
(Issue #9).
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. Most amounts have been rounded to the nearest dollar.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference. The
principal place of business of PKV&S was in Sarasota, Florida, at
the time that the petition was filed at docket No. 5836-99. The
principal place of business of PKVI LP was in Tampa, Florida, at
the time that the petition was filed at docket No. 6395-99. The
Roses resided in Florida at the time that the petition was filed
at docket No. 10154-99.
Background
A. Rose
Rose obtained a bachelor’s degree in physics from Lancaster
University in England, an M.B.A. and a master’s degree in
Page: 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