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In addition to the wages discussed below, PK Ventures
provided health insurance to Rose and his family during the years
in issue. Sometime in 1991, PK Ventures purchased a Honda Civic
and provided that car to Rose. PK Ventures replaced the Honda
Civic with a Mercedes Benz in 1993 and provided the Mercedes Benz
to Rose throughout that year and the remaining years in issue.
Rose determined that PK Ventures would not provide him with any
retirement benefits.
A. Wages Received From Printon Kane and the Printon Kane
Group
Rose’s salaries from Printon Kane during 1986, 1987, and
1988 were $65,000, $67,500, and $65,000, respectively. In 1989,
Rose received salaries from Printon Kane and the Printon Kane
Group totaling $34,423 and $12,115, respectively. In 1990, Rose
received a salary from the Printon Kane Group totaling $6,923.
Rose did not receive any compensation from either Printon Kane or
the Printon Kane Group after 1990.
B. Wages Recorded on PK Ventures’ Books and Records
PK Ventures’ general ledger for 1990 indicated that, during
1990, PK Ventures paid Rose compensation totaling $350,000.
PK Ventures’ general ledger for 1990 also indicated that, of this
$350,000, PK Ventures had accrued $65,000 prior to 1990 and that
SLPC, TBPC, and TPTC had accrued the balance prior to and during
1990 in the following proportions:
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