Estate of H.A. True, Jr. - Page 78




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          shareholders’ tax obligations on their distributive shares of               
          taxable income.                                                             
              Belle Fourche stock has never been traded in public markets.            
          III.  Eighty-Eight Oil                                                      
              On brief, respondent adopted Mr. Kimball’s marketable                   
          minority value for Eighty-Eight Oil of $25,174,683 as of                    
          January 1, 1993; Mr. Lax’s marketable minority value was $40                
          million as of June 3, 1994.                                                 
              During the period 1988 through 1993, Eighty-Eight Oil’s                 
          revenues increased from $191.7 million in 1988 to $558.6 million            
          in 1992, then decreased to $466.7 million in 1993.  Operating               
          margins varied over the analyzed period from 2 percent of                   
          revenues in 1988 to .8 percent in 1993.                                     
              Eighty-Eight Oil generally was profitable from 1988 to 1993,            
          generating the highest ordinary income of $4.1 million in 1992              
          and the lowest of $623,000 in 1988; however, the company                    
          sustained a $7 million loss in 1991.  During the period, Eighty-            
          Eight Oil annually deducted, in arriving at ordinary income, an             
          average of $1.2 million in total guaranteed payments to partners.           
              For the 6 months ending June 30, 1994, Eighty-Eight Oil’s               
          revenues declined from $242 million (for 6 months ending June 30,           
          1993) to $161 million.  However, Eighty-Eight Oil so managed its            
          expenses that ordinary income increased as compared with the same           
          6-month period in 1993.                                                     







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