Estate of Holl v. Commissioner
United States Tax Court
P elected the alternate valuation date under sec. 2032(a)(1), I.R.C., for estate tax purposes. The estate included various interests in oil and gas properties. P calculated the in-place value of oil and gas reserves produced and sold between decedent's date of death and the alternate valuation date by applying a risk reduction factor to the present value of the projected future net cash-flow.
Read the full summary
P elected the alternate valuation date under sec. 2032(a)(1), I.R.C., for estate tax purposes. The estate included various interests in oil and gas properties. P calculated the in-place value of oil and gas reserves produced and sold between decedent's date of death and the alternate valuation date by applying a risk reduction factor to the present value of the projected future net cash-flow. Held, application of the risk reduction factor to the daily production was not justified.
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
95 T.C. 566; 1990 U.S. Tax Ct. LEXIS 108; 95 T.C. No. 39; 113 Oil & Gas Rep. 389;
November 28, 1990, Filed
Decision will be entered under Rule 155.
P elected the alternate valuation date under sec. 2032(a)(1), I.R.C., for estate tax purposes. The estate included various interests in oil and gas properties. P calculated the in-place value of oil and gas reserves produced and sold between decedent's date of…
2Cases cited11 opinions
- United States v. CartwrightSupreme Court of the United States · 1973
- Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Estate of Andrews v. CommissionerUnited States Tax Court · 1982
- Estate of Hall v. CommissionerUnited States Tax Court · 1989
- Chester D. Tripp, Chester D. Tripp, Surviving Spouse Etc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1964
6 more not listed; retrieve them via the Exa API.