Estate of H.A. True, Jr. - Page 81




                                       - 164 -                                        
          value of his capital account as of the close of business on                 
          December 31, 1992, or $7,046,509.  Thus, he sold 24.84 percent              
          out of his 68.47-percent interest in profits, losses, and capital           
          for $2,556,379.  The consideration paid by the True sons for an             
          aggregate 24.84-percent interest in Eighty-Eight Oil represented            
          5.86 percent of total partners’ capital as of December 31, 1992.            
          As a result of the sales, the True sons’ profit and loss sharing            
          ratios each increased by 8.28 percent, for a total increase of              
          24.84 percent.56  If Dave True had not made the $6 million                  
          capital contribution to Eighty-Eight Oil on December 31, 1992,              
          the price he would have been entitled to receive for the 24.84-             
          percent partnership interest would have been less than $400,000.            
              General partnership interests in Eighty-Eight Oil have never            
          been traded in public markets.                                              
          IV.  Black Hills Trucking                                                   
              Respondent has adopted the final Lax report’s controlling               
          equity value (using the net asset value method) of $10,933,730 as           
          of June 3, 1994.                                                            
              Black Hills Trucking engaged in interstate transport of                 
          oilfield and drilling equipment, specializing in on-road and off-           
          road hauling of heavy equipment.  From 1988 to 1994, Black Hills            
          Trucking conducted 75 percent of its business with unrelated                



               56Because of the state of the record, we were unable to                
          perform a similar analysis of partners’ capital account balances            
          in connection with the June 4 and June 30, 1994, transfers.                 




Page:  Previous  154  155  156  157  158  159  160  161  162  163  164  165  166  167  168  169  170  171  172  173  Next

Last modified: May 25, 2011