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Rose was paid $360,537 for his services to PK Ventures and its
subsidiaries during 1986 through 1991. The record establishes,
however, that Rose received $740,537 for his services to
PK Ventures and its subsidiaries during 1986 through 1991. In
addition, PK Ventures provided health insurance to Rose and his
family during those years, PK Ventures provided Rose with a
company car beginning in 1991, and Rose received equity interests
in both PK Ventures and PKVI LP as part of his compensation for
organizing those investment opportunities for Printon Kane.
Accordingly, petitioners’ assertion is incomplete and inaccurate.
Petitioners also claim that the amounts of deferred
compensation listed in PK Ventures’ general ledger for 1992
establish that Rose was not sufficiently compensated for the
services that he performed for PK Ventures and its subsidiaries
during 1986 through 1991. After considering, inter alia, Rose’s
testimony as to the manner in which he “calculated” the deferred
compensation amounts listed in PK Ventures’ general ledger for
1992, the lack of any contemporaneous accounting for these
amounts prior to 1992, and the failure to list these amounts as
liabilities in both PKV&S’s consolidated financial statements and
consolidated income tax returns, we are not persuaded that these
amounts represented compensation that Rose was owed for his
services to PK Ventures and its subsidiaries during 1986 through
1991. Rather, we conclude that the health insurance, company
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