PK Ventures, Inc. and Subsidiaries, et al. - Page 142

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          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.                






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