Estate of Richard R. Simplot - Page 64




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          premium (expressed as a percentage of the equity value of J.R.              
          Simplot Co.) to be accorded the class A voting stock.                       
               In determining the proper equity value of J.R. Simplot Co.,            
          Mr. Much and Dr. Spiro used similar approaches.  They began by              
          valuing J.R. Simplot Co. exclusive of its Micron Technology holding         
          and later added the value of the Micron Technology holding.  In             
          determining the equity value of J.R. Simplot exclusive of its               
          Micron Technology holding, both used the income and market                  
          approaches and averaged the two values obtained.  Excluding the             
          investment for Micron Technology and the reduction for short-term           
          debt, the values that Mr. Much and Dr. Spiro determined are not             
          materially different.  These values can be summarized as follows:           
          Income Approach         Market Approach                                     
          Mr. Much                                                                    
          Total Invested Capital          $1,079,900,000          $1,066,740,000      
          Plus Cash                           31,232,000              31,232,000      
          1,111,132,000           1,097,972,000                                       
          Less:  Long-term debt             (375,536,000)           (375,536,000)     
          Net value                       735,596,000             722,436,000         
          Dr. Spiro                                                                   
          Net value                       720,926,000             719,809,000         
                                                                                     
               As is discernible from this chart, under the income approach           
          the values are within 2 percent of each other, and under the market         
          approach the difference is less than 1 percent.  Dr. Spiro's                
          average of the two values is $720,000,000 (rounded), which is               
          approximately 1 percent less than Mr. Much's average value of               
          $729,016,000.                                                               
               The nominal disparity in their respective equity values arises         
          from adjustments Mr. Much made for the Company's short-term debt            
          ($188,882,000) and for a 6-percent minority discount in valuing the         


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