Estate of Richard R. Simplot, Deceased John Edward Simplot, Personal Representative v. Commissioner of Internal Revenue

OPINION

NOONAN, Circuit Judge:

The Estate of Richard R. Simplot (the Estate) appeals the judgment of the Tax Court determining an estate tax deficiency of $2,162,052. We hold that the Tax Court erroneously attributed a premium to minority voting stock in the J.R. Simplot Co. (Simplot). Accordingly, we reverse the judgment of the Tax Court and remand.

BACKGROUND AND PROCEEDINGS

Simplot is headquartered in Boise, Idaho and incorporated in Nevada. It processes frozen food, in particular potatoes; mines, processes and sells phosphate fertilizer; owns large numbers of cattle and sells beef; and owns…