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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 and
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