- 63 - or TPTC from PKVI LP on PKV&S’s consolidated income tax return for 1989. e. 1990 Contrary to the terms of the PKVI LP promissory notes, Note D to PKVI LP’s audited financial statements for the year ended December 31, 1990, stated that the transfers that had been received by PKVI LP from PK Ventures (totaling $1,096,250) did not bear interest. Note D also stated that there was no stated maturity date with respect to these transfers and that PKVI LP anticipated that it would repay PK Ventures when cash was available. On the Balance Sheets included in these financial statements, $1,096,250 “DUE TO AFFILIATED COMPANY” was listed as a liability. On the Schedule L attached to PKVI LP’s Form 1065 for 1990, $1,096,250 “DUE TO AFFILIATED COMPANIES” was listed under “Other liabilities” as of the end of that year. On its Form 1065 for 1990, PKVI LP reported imputed interest payments totaling $67,772. 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 1990. Note C to the audited consolidated financial statements of PKV&S for the year ended December 31, 1990, stated the following: The Company has a receivable of $1,096,250 from PK Ventures I Limited Partnership (“LTD”) in which it has a 1% general partnership interest and a 29% limited partnership interest. The Company’s investment in andPage: Previous 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 Next
Last modified: May 25, 2011