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therefore, in calculating a discount for lack of marketability a
willing buyer and seller could not have relied upon it.
Dr. Bajaj's sample consisted of 157 observed transactions from
January 1, 1980, to October 31, 1996. Seventy-eight of the
transactions preceded the gift date, and 79 were announced
subsequent to the gift date. Petitioners' reliance on Estate of
Newhouse v. Commissioner, supra, and Estate of Mueller v.
Commissioner, supra, is misplaced. In Estate of Newhouse we
held: "[t]he focus of a valuation inquiry * * * is on the
existing facts, circumstances, and factors at the valuation date
that influence a hypothetical willing buyer and willing seller in
determining a selling price." Estate of Newhouse v.
Commissioner, 94 T.C. at 231. It is not improper, however, to
consider later events to the extent that such events may shed
light upon a fact, circumstance, or factor as it existed on the
valuation date. See, e.g., Estate of Gilford v. Commissioner,
88 T.C. 38, 52-53 (1987). We do not interpret Dr. Bajaj to have
opined that a willing buyer and a willing seller would or could
have relied upon the data he used on the gift date. Instead,
Dr. Bajaj testified that, based on a survey and examination of
similar transactions, including transactions that occurred after
the gift date, we can determine with reasonable accuracy what
willing buyers and willing sellers were doing on the valuation
date. Dr. Bajaj testified
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