The IRS appears to have become more aggressive and sophisticated with respect to oil and gas mineral valuation, especially non-producing mineral valuation. One trust administrator told us that a Form 706 was filed with a non-producing mineral valuation of a token $1 per property and the IRS refuted the valuation; this was the first time this administrator had seen the IRS reject a valuation of non-producing minerals. Applying a nominal value to non-producing minerals is common because of the difficulty valuing such interests. Because of the proliferation of shale and other plays, some non-producing minerals, which had remained dormant for many years, have become very valuable if located near new drilling activity. In such cases, we often rely on a petroleum engineer to help us model potential cash flows from the mineral interest. In other cases, we utilize historical transaction data made available to us by EnergyNet.com, Inc., a marketplace for oil and gas property transactions (www.EnergyNet.com). To assist us in a recent valuation of central Oklahoma non-producing mineral interests, EnergyNet was able to provide 26 non-producing mineral transactions in the area during the two years prior to our valuation date. The average transaction size was 4.5 net mineral acres (which would equate to a 5% mineral interest in a 90 acre gross mineral tract) and the average sale price was approximately $2,100. While these values are relatively small, it does show that non-producing minerals have value. Obviously, as the amount of acreage increases, the values can become material. We have been providing such opinions of value for a number of years and have developed a high level of expertise in valuing these interests and oil and gas interests of all types.