Estate of Richard R. Simplot - Page 24




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          class A voting stock from the reported $47,700 (or $2,650 per               
          share) to $14,435,907 (or $801,994.83 per share) and increased the          
          value for the 3,942.048 class B nonvoting stock from the reported           
          $10,446,427 (or $2,650 per share) to $14,134,213 (or $3,585.50 per          
          share).  These values resulted in the following determined                  
          increases to decedent's gross estate:                                       
                         Amount              Amount         Increases                 
                        reported by     determined by    to gross                     
                    the estate       respondent        estate                         
          18 shares of                                                                
          class A voting                                                              
          shares                $47,700      $14,435,907    $14,388,207               
          3,942.048 shares                                                            
          of class B                                                                  
          nonvoting shares   10,446,427       14,134,213       3,687,786              
          Total disputed increases                         18,075,993                 
               On brief, respondent concedes that the values of decedent's            
          class A and class B shares do not exceed $11,090,094 and                    
          $13,887,007, respectively.                                                  
               In addition, respondent decreased the amount of the marital            
          deduction from the reported $15,127,237 to $1,723,437, because of           
          (1) respondent's redetermination of the fair market value of the            
          class A voting stock and (2) the resulting estate tax consequences          
          which are to be borne by that portion of the estate (the residue)           
          passing to decedent's surviving spouse.  And finally, respondent            
          determined that petitioner is liable for $7,057,554 in penalties            
          pursuant to section 6662(a), (g), (h)(1) and (2)(C).                        





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