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beginning on the date Exxon paid the judgment in Exxon I
(February 27, 1986) and continuing until the judgment date in the
Jarvis Christian litigation, and thereafter for postjudgment
interest.
On July 12, 1991, the executor of decedent's estate filed a
United States Estate (and Generation-Skipping Transfer) Tax
Return (Form 706). On the return, the entire $2,482,719 sought
by Exxon was deducted as a claim against the estate pursuant to
section 2053(a)(3).
On September 10, 1991, the special master in the Jarvis
Christian litigation issued an order regarding the procedures to
be followed in determining the damages, if any, concerning each
defendant. On September 23, 1991, the Allen parties filed a
response to the special master's order, wherein they objected to
Exxon's damage calculations.
On February 10, 1992, petitioner and Exxon entered into a
settlement agreement with respect to the litigation. Pursuant to
the settlement, petitioner paid Exxon $421,276.60 and surrendered
to Exxon for a period of 7 years Frankie Allen's royalty interest
in the HFU, which had a fair market value of approximately
$260,563.00 when assigned. Petitioner thus resolved Exxon's
disputed claim for a total amount of $681,839.60. On April 6,
1992, Exxon and the Allen parties filed a stipulation of
dismissal. On April 29, 1992, the District Court ordered that
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Last modified: May 25, 2011