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date, see Estate of Scanlan v. Commissioner, T.C. Memo. 1996-331
(adjustments made to redemption price to account for passage of
time, as well as the change in the setting from the date of the
decedent’s death to the date of the redemption), affd. without
published opinion 116 F.3d 1476 (5th Cir. 1997), we believe they
are relevant to our determination of that fair market value. See
Estate of Gilford v. Commissioner, 88 T.C. 38, 52 (1987); Estate
of Jephson v. Commissioner, 81 T.C. 999, 1002 (1983); see also
Estate of Van Horne v. Commissioner, 720 F.2d 1114, 1116 (9th
Cir. 1983), affg. 78 T.C. 728 (1982); Estate of Scanlan v.
Commissioner, supra. That the Sterling preferred stock would be
redeemed on or before the December 31, 1995, date set forth in
the purchase agreement, at or about the price stated therein, was
foreseeable on September 18, 1992, based on the facts available
on that date. Doherty v. Commissioner, supra at 340. The estate
is mistaken in asserting that Sterling's financial position was
too weak on September 18, 1992, to effectuate a redemption of the
Sterling preferred stock on or after that date. Sterling's 1990
through 1992 cash-flow was positive, and its losses for 1990 and
1991 stemmed mainly from its amortization of intangible assets
and deferred financing costs. Sterling's loss in 1991 was also
attributable to the one-time writeoff of $2,953,646, an expense
that sprang automatically from the death of a party subject to
the underlying noncompetition agreement. Sterling also realized
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