- 19 - 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...)Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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