Estate of Richard R. Simplot - Page 25




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                              ULTIMATE FINDINGS OF FACT                               
               1.   The class A voting stock is to be accorded a premium for          
          its voting privileges.  After giving consideration to the premium           
          for the voting privileges, and after applying a 35-percent                  
          marketability (lack of liquidity) discount, the fair market value           
          of decedent's class A voting stock was $215,539.01 per share or a           
          total of $3,879,702.19, on the valuation date.                              
               2. After applying a 40-percent marketability (lack of                  
          liquidity) discount, the fair market value of decedent's class B            
          nonvoting stock was $3,417.05 per share or a total of                       
          $13,470,190.88, on the valuation date.3                                     
               3.   Because there has been no payment of State transfer or            
          inheritance taxes, respondent correctly did not include in the              
          computation of the amount of the marital deduction (and in the              
          computation of the asserted estate tax deficiency) an allowance for         
          State transfer or inheritance taxes paid.                                   
               4.   Petitioner acted reasonably and in good faith in relying          
          on the advice of tax professionals and appraisers in valuing                
          decedent's class A voting stock and class B nonvoting stock for             
          Federal estate tax purposes.                                                




               3    In arriving at the valuations in Ultimate Findings of             
          Fact Nos. 1 and 2, we did not consider certain exhibits (Exs. 22-           
          J, 30-R, 41-J, 42-J, 43-J, 44-J, 45-J, 46-J, 121-P, 124-P, 125-P,           
          126-P, 127-P, and 128-P) that the parties objected to in the                
          stipulations of facts.  These documents are not probative and               
          accordingly have been accorded no weight.                                   


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