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valuation date. Estate of Jung v. Commissioner, 101 T.C. 412,
431 (1993). In short, evidence as to latter category of events
may be admitted because of its potential relevance even though it
may ultimately be determined that such evidence does not have an
impact on the determination of fair market value.
Here again, we see no purpose to be served by analyzing each
stipulation, exhibit, or testimony relating to post-May 1983
events. These items include matters not only relating to the
1985 and 1990 sales of the hospital, but also the payments made
to and from petitioner's pension plan which was transferred as
part of the 1983 sale, sales of the Belcher Road and County Road
#77 parcels, and the AMH 1984 audit report. We think it
sufficient to observe that the evidence to which petitioner
objects may be relevant to our determination herein, i.e., to the
extent that other evidence could provide a basis for concluding
that the elements which impacted the 1985 sale may have been
sufficiently known or anticipated at the time of the 1983 sale.
We previously ruled twice that such evidence was admissible,
reserving to petitioner the right to reargue its position on
brief. This petitioner has done, but we remain unpersuaded.
Accordingly, petitioner's objections to evidence relating to
post-1983 events are overruled. We likewise overrule
petitioner's objections to the other described material on the
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