Estate of Richard R. Simplot - Page 4




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               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.                                                        



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