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               In these cases, the parties dispute the reasonableness of              
          the total compensation paid to Rose by PK Ventures and its                  
          subsidiaries during 1992 and 1993 and deducted by PKV&S on its              
          consolidated income tax returns for those years.  Petitioners               
          contend that the amounts that PKV&S deducted as compensation paid           
          to Rose in 1992 and 1993 were reasonable because (1) a                      
          significant portion of these amounts was intended to be                     
          deductible as compensation for services that Rose performed for             
          PK Ventures and its subsidiaries during 1986 through 1991 and               
          (2) an analysis of the facts and circumstances of these cases               
          establish that these amounts were reasonable.  Conversely,                  
          respondent contends that the amounts that PKV&S deducted as                 
          compensation paid to Rose in 1992 and 1993 were not reasonable              
          because (1) petitioners have failed to establish that a                     
          significant portion of these amounts was intended to be                     
          deductible as compensation for services that Rose performed for             
          PK Ventures and its subsidiaries during 1986 through 1991 and               
          (2) the testimony provided by petitioners’ expert witness                   
          establishes that these amounts were not reasonable.  We address             
          the parties’ contentions below.                                             
               Petitioners contend that a significant portion of the                  
          compensation that Rose received from PK Ventures and its                    
          subsidiaries during 1992 and 1993 was intended to be deductible             
          as compensation for services that Rose performed for those                  
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