- 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
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