Legal Opinion

Estate of Holl v. Commissioner

United States Tax Court

Decided November 15, 1993No. Docket No. 6039-89Published

In Estate of Holl v. Commissioner, 967 F.2d 1437 (10th Cir. 1992), revg. 95 T.C. 566 (1990), this case was remanded for a revised determination of the value of in-place oil and gas reserves extracted between the date of death and the alternate valuation date under sec. 2032(a)(1), I.R.C.Held, the determination of value should include a minimal discount for risk or uncertainty, as set forth in respondent's expert report.

1Opinion of the Court

Estate of F.G. Holl, Deceased, Bank IV Wichita, N.A., Executor, Petitioner v. Commissioner of Internal Revenue, Respondent *

Estate of Holl v. Commissioner

Docket No. 6039-89

United States Tax Court

101 T.C. 455; 1993 U.S. Tax Ct. LEXIS 70; 101 T.C. No. 29; 127 Oil & Gas Rep. 655;

November 15, 1993, Filed

Decision will be entered under Rule 155.

In Estate of Holl v. Commissioner, 967 F.2d 1437 (10th Cir. 1992), revg. 95 T.C. 566 (1990), this case was remanded for a revised determination of the value of in-place oil and gas reserves extracted between the date of death and the alternate valuation date…

2Cases cited6 opinions

  1. Maass v. HigginsSupreme Court of the United States · 1941
  2. Estate of F.G. Holl, Deceased and Bank IV Wichita, N.A. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1992
  3. The Estate of Nellie S. Johnston, Deceased, by Robert B. Payne, Independent v. United StatesCourt of Appeals for the Fifth Circuit · 1986
  4. Estate of Holl v. CommissionerUnited States Tax Court · 1990
  5. Flanders v. United StatesDistrict Court, N.D. California · 1972

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