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Co.'s 5-year strategic business plan also projected a favorable
outlook for the Company.
Both before and after the valuation date, several of J.R.
Simplot Co.'s competitors had inquired into whether the Company or
parts of the Company might be available for acquisition.
I. Decedent's Last Will and Testament
Pursuant to the terms of his will, executed on July 13, 1988,
decedent bequeathed to the trustees of a testamentary trust for the
benefit of his children (the credit shelter trust) all of his J.R.
Simplot Co. class A voting stock plus that amount of class B
nonvoting stock which, when added to the voting stock (as valued
for Federal estate tax purposes), equaled the Federal estate tax
return filing requirement amount in effect at the time of his death
(i.e., $600,000), reduced by the aggregate amount of any adjusted
taxable gifts (as defined in section 2001(b)) made by him after
December 31, 1976. The balance of decedent's estate, including the
remaining class B nonvoting shares owned by decedent, passed to
decedent's surviving spouse, Adelia Ann Simplot.
Federal estate tax due from decedent's estate is to be paid
out of that portion of the estate which is to otherwise pass to
decedent's surviving spouse. All State transfer and inheritance
taxes due with respect to a bequest are treated as a charge against
the distributive share of the person receiving the bequest.
J. U.S. Estate Tax Return
In September 1994, petitioner filed a Form 706, United States
Estate (and Generation-Skipping Transfer) Tax Return, that listed
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