- 87 - PKV&S reported the following amounts with respect to PK Ventures’ and/or its subsidiaries’ interests in PKVI LP on its consolidated income tax returns for 1987 through 1993: Income (Loss) Cancellation of Year from PKVI LP Bad Debts Indebtedness Income 1986 ($1,323) -– -– 1987 (2,036) -– -- 1988 (18,515) -– -– 1989 (26,497) -– —- 1990 (124,687) -- -- 1991 (181,271) $1,516,246 $454,874 1992 (251,921) -– -- 1993 (212,893) -– -- C. IRS Determinations The IRS determined that PKV&S could deduct PK Ventures’ distributive share of PKVI LP’s losses for 1990, 1991, 1992, and 1993 to the extent of PK Ventures’ basis in its PKVI LP interest. Before taking into account any of PKVI LP’s losses, the IRS determined that PK Ventures’ basis in its PKVI LP interest was $114,936 as of December 31, 1990. The IRS determined this amount by subtracting the amount of PKVI LP’s losses that PKV&S deducted in 1986, 1987, 1988, and 1989 from the cash advances that it determined that PK Ventures had made to PKVI LP in 1990 and prior years and the capital contribution that it determined that PK Ventures had made to PKVI LP in 1988. The IRS allowed as a deduction against this basis $114,936 of PK Ventures’ distributive share of PKVI LP’s losses for 1990. Accordingly, the IRS increased PKV&S’s taxable income by $9,751 for 1990.Page: Previous 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 Next
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