- 4 -
All section references are to the Internal Revenue Code in
effect as of the date of decedent's death, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulations
of facts are incorporated in our findings by this reference.
A. Background
Decedent, a resident of Boise, Idaho, died testate on June 24,
1993. He was 59 years old. At the time the petition was filed
herein, John Edward Simplot, decedent's son and personal
representative, resided in Boise, Idaho.
Decedent and his siblings are the children of Jack R. Simplot
(J.R. Simplot), who was living on the trial date of this case. At
the time of his death, decedent owned 18 shares of class A voting
common stock (class A voting stock) and 3,942.048 shares of class
B nonvoting common stock (class B nonvoting stock) of J.R. Simplot
Co., constituting 23.55 percent of the outstanding shares of class
A voting stock and 2.79 percent of the outstanding shares of class
B nonvoting stock. The remaining shares of class A voting stock
were owned by decedent's siblings: Gay C. Simplot Otter (Gay), Don
J. Simplot (Don), and Scott R. Simplot (Scott). As of the date of
decedent's death, virtually all of the shares of class B nonvoting
stock were owned, directly or indirectly, by the descendants of
J.R. Simplot and an Employee Stock Ownership Plan (ESOP)
established in 1978.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011