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offer was for all of Eatel’s stock, are factors that we must
consider in harmonizing the offering and redemption prices with
the value of the subject shares on the Valuation Dates. We
recognize that the value of the subject shares must be determined
as of the Valuation Dates, and that the probative weight of
future events must be discounted accordingly. Sec. 20.2031-1(b),
Estate Tax Regs.; see also Estate of Jung v. Commissioner, supra
at 430-432; Estate of Newhouse v. Commissioner, 94 T.C. 193, 218
(1990). As this Court stated in Estate of Jung v. Commissioner,
supra at 431-432:
for purposes of determining fair market
value, we believe it appropriate to consider
sales of properties occurring subsequent to
the valuation date if the properties involved
are indeed comparable to the subject
properties. * * *
Of course, appropriate adjustments must
be made to take account of differences
between the valuation date and the dates of
the later-occurring events. For example,
there may have been changes in general
inflation, people’s expectations with respect
to the industry, performances of the various
components of the business, technology, and
the provisions of tax law that might affect
fair market values * * * [between the
valuation date and the subsequent date of
sale]. Although any such changes must be
accounted for in determining the evidentiary
weight to be given to the later-occurring
events, those changes ordinarily are not
justification for ignoring the later-
occurring events (unless other comparables
offer significantly better matches to the
property being valued). [Citations and
quotation marks omitted.]
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