Estate of Richard R. Simplot - Page 1

                                   112 T.C. No. 13                                    

                               UNITED STATES TAX COURT                                

                       PERSONAL REPRESENTATIVE, Petitioner v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 23122-97.                   Filed March 22, 1999.           

                    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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