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the value of the property should not be considered in
fixing fair market value. See First Natl. Bank of Kenosha
v. United States, 763 F.2d 891, 893-894 (7th Cir. 1985).
However, this Court has drawn a distinction between
subsequent events which affect the value of the property
and those which merely provide evidence of such value on
the valuation date. See Estate of Jung v. Commissioner,
101 T.C. 412, 431 (1993).
Subsequent events or conditions which affect the value
of the property can be taken into account only if they are
reasonably foreseeable on the valuation date. Id. For
example, the discovery of oil on real property after the
valuation date could affect what a willing buyer would pay
and what a willing seller would demand for the property on
the valuation date if the buyer and seller could foresee
the discovery. If the discovery was unforeseeable on the
valuation date, then it could not affect the value of the
property on the valuation date and should not be considered
in determining the value of the property on that date. See
id.; Estate of Hillebrandt v. Commissioner, T.C. Memo.
1986-560.
Conversely, subsequent events which merely provide
evidence of the value of the property on the valuation
date can be taken into account regardless whether they
are foreseeable on the valuation date. See id. Estate of
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