Estate of Simplot v. Comm'r
United States Tax Court
I. Decedent owned 18 of the outstanding 76.445 shares of the voting stock and 3,942.048 of the outstanding 141,288.584 shares of the nonvoting stock of J.R. Simplot Co. (the Company), a private, family-owned corporation. The remaining shares of outstanding voting stock were owned by decedent's three siblings. The voting stock is subject to a 360-day restriction on transferability or hypothecation.
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I. Decedent owned 18 of the outstanding 76.445 shares of the voting stock and 3,942.048 of the outstanding 141,288.584 shares of the nonvoting stock of J.R. Simplot Co. (the Company), a private, family-owned corporation. The remaining shares of outstanding voting stock were owned by decedent's three siblings. The voting stock is subject to a 360-day restriction on transferability or hypothecation. Both classes of stock are entitled to the same dividends (without preference) on a per-share basis, if and when dividends are declared. Holders of the nonvoting stock are entitled to a liquidating…
1Opinion of the Court
Jacobs, Judge:
Respondent determined a $17,643,886 deficiency in petitioner’s Federal estate tax and $7,057,554 in penalties pursuant to section 6662(a), (g), and (h)(1) and (2)(C).
Following a concession by respondent, the issues for decision are: .(l) The fair market value of 18 shares of class A voting common stock of J.R. Simplot Co. owned by Richard R. Simplot (decedent) on June 24, 1993 (the valuation date); (2) the fair market value of 3,942.048 shares of class B nonvoting common stock of J.R. Simplot Co. owned by decedent on the valuation date; (3) the amount of the section 2056 marital…
2Cases cited37 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Helvering v. TaylorSupreme Court of the United States · 1935
- United States v. CartwrightSupreme Court of the United States · 1973
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- Michael L. Rockwell, and Regina Rockwell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
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