Estate of H.A. True, Jr. - Page 173




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              We find that a minority interest in Eighty-Eight Oil was not            
          fully marketable at the valuation dates because:  (1) The True              
          family was committed to keeping Eighty-Eight Oil privately owned;           
          (2) there were risks that a purchaser would not obtain unanimous            
          consent to be admitted as a partner; and (3) a purchasing partner           
          would be exposed to joint and several liability.                            
              However, a minority interest in Eighty-Eight Oil would be               
          more marketable than an equivalent interest in True Oil or in               
          comparable public companies.  Unlike True Oil, Eighty-Eight Oil             
          was profitable and consistently made guaranteed payments to its             
          partners, who considered the company to be a “cash cow”.                    
          Furthermore, during the period being examined, Eighty-Eight Oil             
          was more liquid than the industry, and the concepts of liquidity            
          and marketability are closely related.  Finally, a general                  
          partner in Eighty-Eight Oil would exert more control over the               
          business than a shareholder would in a comparable public company.           
          Under the WUPA, partnership agreements generally govern relations           
          among the partners and between the partners and the partnership.            
          See Wyo. Stat. Ann. sec. 17-21-103(a) (Michie 1999).  Eighty-               
          Eight Oil’s partnership agreement required the partners to manage           
          jointly the partnership’s affairs.  Thus under Wyoming law, each            
          partner had an equal vote in (among other things) appointing                
          management, setting business policies, making distributions,                
          buying and selling assets, and amending the partnership                     







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