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ESTATE OF SIMPLOT v. COMMISSIONER

Docket No. 23122-97.

112 T.C. 130 (1999)

ESTATE OF RICHARD R. SIMPLOT, DECEASED, JOHN EDWARD SIMPLOT, PERSONAL REPRESENTATIVE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 22, 1999.

Attorney(s) appearing for the Case

David John Thornton, Gregory Allen Byron, and Sheldon I. Fink, for petitioner.

David J. Mungo and Robert A. Varra, for respondent.

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: (1) 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...

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