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joint income tax return for 1990 and shifting $13,000 of the
compensation that Rose reported in 1991 to 1990, the IRS
increased the Roses’ taxable income for 1990 by $320,000.
With respect to 1991, the IRS determined that Rose should
have reported an additional $97,469 of compensation from
PK Ventures and its subsidiaries. The IRS determined that this
amount included $60,000 of compensation that had been accrued by
TBPC and TPTC during 1991 and included $37,469 of compensation
that had been accrued by PK Ventures during that year.
Accordingly, the IRS increased the Roses’ taxable income for 1991
by $97,469.
The Roses conceded these adjustments for 1990 and 1991.
Taking into account these concessions, Rose received the
following amounts of compensation for his services to PK Ventures
and its subsidiaries during 1986 through 1991:
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