Estate of Richard R. Simplot - Page 65




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          Company's Micron Technology holding.  Mr. Much valued J.R. Simplot          
          Co. by reviewing financial statements for the 5 fiscal years ended          
          August 1988 through 1992, and for the 9-month period ended May              
          1993.  The adjustments he made to his values for cash and debts of          
          the Company were derived from information on the quarterly                  
          financial statement for the quarter ended May 1993.                         
              J.R. Simplot Co.'s controller, James D. Crawford, testified            
          that Mr. Much improperly failed to account for the seasonally high          
          levels of the Company's receivables and inventory.  According to            
          Mr. Crawford, because the Company's business was seasonal, its              
          financial statements from one quarter to another were not                   
          comparable.  Mr. Crawford explained that the Company's balance              
          sheet for the quarter ending in May would have higher levels of             
          inventory, receivables, and short-term debt than its balance sheet          
          for the year ending in August.  (The high levels of inventory and           
          receivables were financed with working capital, resulting in high           
          short-term debt.)  Mr. Crawford estimated that the Company's short-         
          term debt would have varied by approximately $150 million between           
          May and August 1993.  We found Mr. Crawford a credible witness.             
               Mr. Much admitted at trial that if the seasonal changes in             
          short-term debt were not taken into consideration the equity value          
          as of August 1993 would be approximately $113,000,000 higher than           
          his value as of late June 1993.  We believe that the high short-            
          term debt of the Company as of May 1993 is an aberration, and as a          
          result it should not have been taken into account.                          



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