Eugene D. Lanier, Inc. - Page 19

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               Events occurring subsequent to the valuation date are not              
          considered in determining FMV of the property, except to the                
          extent the events are reasonably foreseeable on the valuation               
          date.  See First Natl. Bank of Kenosha v. United States, 763 F.2d           
          891, 893-894 (7th Cir. 1985); Estate of Spruill v. Commissioner,            
          88 T.C. at 1228.  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 which affect the value of the           
          property (such as the discovery of oil on the real property) can            
          be taken into account only if they are reasonably foreseeable on            
          the valuation date.  Estate of Jung, supra.  Conversely,                    
          subsequent events which merely provide evidence of the value of             
          the property on the valuation date can be taken into account                
          regardless of whether they are foreseeable on the valuation date.           
          Estate of Jung v. Commissioner, supra.  In considering such                 
          events, appropriate adjustments must be made for changes in                 
          inflation, general economic conditions and other similar factors.           
          Estate of Jung v. Commissioner, supra.                                      
               The mere fact that the comparables used by Lambert are                 
          subsequent in time to the valuation date is not fatal to                    
          Lambert's determination.2  See Estate of Smith v. Commissioner,             

               2  We are not discrediting Lambert's use of the comparables            
                                                             (continued...)           




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