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1994-641, or “corroborate an appraisal that is based on facts
known as of the valuation date”, Jacobson v. Commissioner, T.C.
Memo. 1989-606. Further, subsequent-year events may be
admissible where relevant as to whether asserted expectations or
prospects (as of the valuation date) were “reasonable and
intelligent.” Estate of Gilford v. Commissioner, 88 T.C. 38, 54
(1987); Estate of Jephson v. Commissioner, 81 T.C. 999, 1002
(1983); Regents Park Partners v. Commissioner, T.C. Memo. 1992-
336.
As explained, in the case herein, for Federal estate tax
purposes, both parties relied on valuation reports to estimate
the date-of-death value of the estate’s 20-percent interest in
TPC. The estate’s experts valued decedent’s interest in TPC at
approximately $1.750 million. Respondent’s expert valued
decedent’s interest at approximately $32.4 million. The large
disparity between the parties’ valuations is startling.
Where conflicting valuations are submitted, a court may give
different weight to the valuations and factors relied on by the
parties. Casey v. Commissioner, 38 T.C. 357, 381 (1962). The
Court is not bound to adopt either party’s valuation carte
blanche and is to reach a decision based on its analysis and its
consideration of the evidence. Helvering v. Natl. Grocery Co.,
304 U.S. 282, 295 (1938); McCord v. Commissioner, 120 T.C. 358,
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