PK Ventures, Inc. and Subsidiaries, et al. - Page 60

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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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