Estate of Holl v. Commissioner
United States Tax Court
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
SUPPLEMENTAL FINDINGS OF FACT AND OPINION
COHEN, Judge:
This case is before us pursuant to the remand of the Court of Appeals for the Tenth Circuit in Estate of Holl v. Commissioner, 967 F.2d 1437 (10th Cir. 1992), revg. 95 T.C. 566 (1990). The sole issue is the in-place value of certain oil and gas reserves as of the date of severance, for purposes of inclusion in the gross estate on the alternate valuation date under section 2032(a)(1). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect as of the date of decedent’s death, and all Rule references are…
2Cases cited5 opinions
- Maass v. HigginsSupreme Court of the United States · 1941
- Estate of F.G. Holl, Deceased and Bank IV Wichita, N.A. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1992
- The Estate of Nellie S. Johnston, Deceased, by Robert B. Payne, Independent v. United StatesCourt of Appeals for the Fifth Circuit · 1986
- Estate of Holl v. CommissionerUnited States Tax Court · 1990
- Flanders v. United StatesDistrict Court, N.D. California · 1972
3Cited by1 opinion
- Estate of Holl v. CommissionerUnited States Tax Court · 1993