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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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