Estate of Richard R. Simplot - Page 62




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          C.  Court's Analysis and Conclusions                                        
               The respective valuation methodologies adopted by the parties'         
          experts produced vastly different results.  Petitioner's experts            
          used a simple, traditional methodology to value an unusual                  
          corporate capital structure, which resulted in little or no premium         
          for voting rights.  On the other hand, respondent's experts used a          
          valuation methodology which, given the Simplot family's philosophy,         
          appears to accord the class A stock an extraordinarily high premium         
          for its voting privileges.                                                  
               Not unexpectedly, petitioner's experts found fault with the            
          analyses and conclusions of respondent's experts and vice versa.            
          We agree that each of the experts' analyses and conclusions is              
          subject, to an extent, to valid criticism.  Specifically, we                
          believe, among other things, the situations involved in the data            
          and studies relied upon by both sets of experts to be so different          
          from the situation involved herein that such data and studies are           
          inapplicable to the case at hand.                                           
               The differing views of the experts as to the proper                    
          methodology to be used in valuing decedent's class A voting shares          
          vis-a-vis his class B nonvoting shares illustrate the difficulty in         
          valuing shares of unlisted stock in a large, family-controlled              
          corporation.  Moreover, those differing views give credence to the          
          belief that valuation is at best an inexact science.                        
               The aforesaid notwithstanding, in fulfilling our task, we deem         
          it proper to value decedent's shares of class A voting and class B          
          nonvoting stock in J.R. Simplot Co. using one of the expert's               

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