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.
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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
COHEN, Judge:
Respondent determined a deficiency of $1,249,427.39 in petitioner’s Federal estate tax. After concessions, the issue for decision is the in-place value of the oil and gas reserves produced and sold between decedent’s date of death and the alternate valuation date under section 2032(a)(1). Unless otherwise indicated, all section references are to the Internal Revenue Code as amended and in effect as of the date of decedent’s death.
FINDINGS OF FACT
Some of the facts have been stipulated, and the facts set forth in the stipulation are incorporated in our findings by this reference.…
2Cases cited10 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
5 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Estate of F.G. Holl, Deceased and Bank IV Wichita, N.A. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1992
- Estate of Friedberg v. CommissionerUnited States Tax Court · 1992
- Estate of Holl v. CommissionerUnited States Tax Court · 1993
- Estate of Holl v. CommissionerUnited States Tax Court · 1993
- Estate of Holl v. CommissionerUnited States Tax Court · 1990