Estate of H.A. True, Jr. - Page 72




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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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