- 145 - 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, companyPage: Previous 135 136 137 138 139 140 141 142 143 144 145 146 147 148 149 150 151 152 153 154 Next
Last modified: May 25, 2011