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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.
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