- 84 - Entity 1986-89 1990 1991 PK Ventures $170,000 $98,068 $67,469 SLPC -- 45,000 -- TBPC –- 120,000 60,000 TPTC -- 120,000 60,000 Total 170,000 383,068 187,469 In sum, Rose received $740,537 for his services to PK Ventures and its subsidiaries during these years. With respect to 1992, the IRS determined that the deduction that PKV&S claimed for compensation paid to Rose should be reduced by $1,208,893. The IRS determined this reduction by subtracting (1) reasonable salary for 1992 totaling $143,317 and (2) deferred compensation totaling $294,738 from the $1,646,948 that PKV&S deducted in that year. The IRS determined the reasonable salary for 1992 by multiplying PKV&S’s gross receipts for that year by 3 percent. The IRS determined deferred compensation as follows: Salary Deducted on Reasonable Deferred Year Return Salary Difference Compensation 1987 -– $91,634 ($91,634) $91,634 1988 -– 120,800 (120,800) 120,800 1989 $170,000 133,739 36,261 (36,261) 1990 50,068 159,024 (108,956) 108,956 1991 140,469 150,078 (9,609) 9,609 Total 360,537 655,275 (294,738) 294,738 As it did in 1992, the IRS determined reasonable salary for 1987 through 1991 by multiplying PKV&S’s gross receipts for each of those years by 3 percent. Accordingly, the IRS increased PKV&S’s taxable income by $1,208,893 for 1992.Page: Previous 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 Next
Last modified: May 25, 2011