Estate of Richard R. Simplot - Page 48




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               B. Valuations of Respondent's Experts                                  
               1.  Herbert T. Spiro                                                   
               Respondent's first expert, Herbert T. Spiro, has been                  
          president of American Valuation Group, Inc., a consulting firm              
          specializing in economic analyses and financial valuations, since           
          1985, as well as a professor of finance at California State                 
          University at Northridge.  In his expert report submitted for               
          trial, Dr. Spiro concluded that as of the valuation date, the fair          
          market value per share of J.R. Simplot Co.'s class A voting stock           
          was $616,116.36, and the value per share of J.R. Simplot Co.'s              
          class B nonvoting stock was $3,522.79 (resulting in the value of 18         
          shares of class A voting stock at $11,090,094 and 3,942.048 shares          
          of class B nonvoting stock at $13,887,007).                                 
               Dr. Spiro's approach in determining an equity value for J.R.           
          Simplot Co. was generally similar to that of Mr. Much.  First, he           
          valued J.R. Simplot Co. exclusive of its Micron Technology                  
          investment and then added the value of the Micron Technology                
          investment to determine the total equity value of J.R. Simplot Co.          
               In determining the value of J.R. Simplot Co. exclusive of its          
          Micron Technology holding, Dr. Spiro (in a manner similar to that           
          of Mr. Much) used both the income and market approaches15 and then          


               15   According to Dr. Spiro, the income approach is based on           
          the premise that a rational buyer of an asset would pay only the            
          equivalent of the present value of the net cash stream realized             
          from the asset.  Future cash inflows and outflows are projected             
          in this analysis and then discounted to the present to yield a              
          value. The market approach presumes that the most an investor               
          will pay for an asset is the price other investors are currently            
                                                             (continued...)           

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