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Stallion, to be valued as of June 4, 1994 (disputed companies).
See Appendix schedules 1-3. The parties have stipulated that the
fair market values of the assets owned by the disputed companies,
except White Stallion, were the same on June 30, 1994, as they
were on June 4, 1994.
Financial information for the disputed companies was
compiled and analyzed in the expert reports, which derived the
data from the companies’ Federal partnership and S corporation
income tax returns for tax years 1988 through 1994. The disputed
companies maintained tax basis books and records for management
purposes and did not have financial statements that had been
audited or otherwise reviewed by certified public accountants.
See supra pp. 12-22 for historical background of disputed
companies.
I. True Oil
True Oil’s proved oil reserves equaled 5,297,528 barrels
(bbl) as of August 1, 1973, and 7,389,000 bbl as of June 4, 1994.
Proved gas reserves were 8,551,994 thousands of cubic feet (Mcf)
as of August 1, 1973, and 9,075,000 Mcf as of June 4, 1994. The
parties have stipulated that the total fair market value of all
oil and gas properties and related facilities owned by True Oil
was $39,650,000 as of January 1, 1993, and $34,200,000 as of June
4, 1994. In addition, respondent agreed not to dispute
petitioners’ position that True Oil’s reserves were 8.9 million
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