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On the Schedule L attached to PKVI LP’s Form 1065 for 1988,
$126,558 “Due to Affiliated Company” was listed under “Other
current liabilities” as of the end of that year. There were no
amounts separately identified as interest payments made and/or
imputed by PKVI LP to PK Ventures, TBPC, or TPTC on its Form 1065
for 1988.
No direct references were made and no explanations were
provided in PK Ventures, TBPC, or TPTC’s financial statements for
the year ended December 31, 1988, as to the amounts that
PK Ventures, TBPC, and TPTC transferred to PKVI LP during that
year.
On the Schedule L attached to PKV&S’s consolidated income
tax return for 1988, PK Ventures, TBPC, and TPTC reported
$118,558 due from PKVI LP under “Other assets” as of the end of
that year. Of this amount, $20,580 was attributable to
PK Ventures, $48,000 was attributable to TBPC, and $49,978 was
attributable to TPTC. There were no amounts separately
identified as interest payments received and/or imputed by
PK Ventures, TBPC, or TPTC from PKVI LP on PKV&S’s consolidated
income tax return for 1988.
d. 1989
Note 4 to PKVI LP’s audited financial statements for the
year ended December 31, 1989, stated, in pertinent part: “At
December 31, 1989, the Partnership owed $448,646 to
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