Estate of Mary D. Maggos - Page 27

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          Estate of Watts v. Commissioner, 823 F.2d 483, 486 (11th Cir.               
          1987), affg. T.C. Memo. 1985-595.  The hypothetical willing buyer           
          and willing seller are presumed to be dedicated to achieving the            
          maximum economic advantage.  See Estate of Curry v. United                  
          States, supra at 1428; Estate of Newhouse v. Commissioner, supra            
          at 218.  This advantage must be achieved in the context of market           
          and economic conditions at the valuation date.  See Estate of               
          Newhouse v. Commissioner, supra at 218.                                     
               For Federal gift tax purposes, the fair market value of the            
          subject property is determined as of the date of the gift.                  
          Ordinarily, no consideration will be given to any subsequent                
          event that may have affected the value of the subject property on           
          some later date if the event was unforeseeable at the time of the           
          gift.  See sec. 2512(a); sec. 20.2031-1(b), Estate Tax Regs.; see           
          also First Natl. Bank v. United States, 763 F.2d 891, 893-894               
          (7th Cir. 1985); Estate of Newhouse v. Commissioner, supra at               
          218; Estate of Gilford v. Commissioner, 88 T.C. 38, 52 (1987).              
          Expert Testimony                                                            
               Both parties rely primarily on expert opinion evidence to              
          support their contrary valuation positions.  We evaluate the                
          opinions of experts in light of the demonstrated qualifications             
          of each expert and all other evidence in the record.  See                   
          Anderson v. Commissioner, 250 F.2d 242 (5th Cir. 1957), affg. in            
          part and remanding in part on another ground T.C. Memo. 1956-178;           

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