Legal Opinion
Estate of Richard R. Simplot v. Commissioner
United States Tax Court
Decided March 22, 1999No. 23122-97Unknown
1Opinion of the Court
112 T.C. No. 13
UNITED STATES TAX COURT ESTATE OF RICHARD R. SIMPLOT, DECEASED, JOHN EDWARD SIMPLOT, PERSONAL REPRESENTATIVE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23122-97. Filed March 22, 1999. 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…
2Cases cited38 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
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
- Michael L. Rockwell, and Regina Rockwell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
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