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Held: Petitioner is not liable for the penalties at
issue because petitioner acted reasonably and in good
faith by relying on the advice of tax professionals and
appraisers.
David John Thornton, Gregory Allen Byron, and Sheldon I.
Fink, for petitioner.
David J. Mungo and Robert A. Varra, for respondent.
JACOBS, Judge: Respondent determined a $17,643,886 deficiency
in petitioner's Federal estate tax and $7,057,554 in penalties
pursuant to section 6662(a), (g), (h)(1), and (2)(C).
Following a concession by respondent, the issues for decision
are: (1) The fair market value of 18 shares of class A voting
common stock of J.R. Simplot Co. owned by Richard R. Simplot
(decedent) on June 24, 1993 (the valuation date); (2) the fair
market value of 3,942.048 shares of class B nonvoting common stock
of J.R. Simplot Co. owned by decedent on the valuation date; (3)
the amount of the section 2056 marital deduction to be allowed the
estate of decedent (petitioner); and (4) whether petitioner is
liable for the section 6662 penalties as determined by respondent.
Subsumed in the resolution of the stock valuation issues is the
question of whether a premium should be accorded the voting
privileges of the class A stock; and, if so, the amount of that
premium.
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