112 T.C. No. 13
UNITED STATES TAX COURT
ESTATE OF RICHARD R. SIMPLOT, DECEASED, JOHN EDWARD SIMPLOT,
PERSONAL REPRESENTATIVE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23122-97. Filed March 22, 1999.
I.
Decedent owned 18 of the outstanding 76.445 shares
of the voting stock and 3,942.048 of the outstanding
141,288.584 shares of the nonvoting stock of J.R. Simplot
Co. (the Company), a private, family-owned corporation.
The remaining shares of outstanding voting stock were
owned by decedent's three siblings. The voting stock is
subject to a 360-day restriction on transferability or
hypothecation. Both classes of stock are entitled to the
same dividends (without preference) on a per-share basis,
if and when dividends are declared. Holders of the
nonvoting stock are entitled to a liquidating preference.
On the estate tax return, the fair market value for
both classes of stock was reported as $2,650 per share.
Petitioner agrees that because of an error by its
appraiser in the calculation of the aggregate number of
outstanding shares, the fair market value for both
classes of stock should have been $3,025 per share. In
the notice of deficiency, respondent determined the fair
market value of the voting stock to be $801,994.83 per
share and the fair market value of the nonvoting stock to
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