Estate of Helen M. Noble, Deceased, Leslie H. Noble, Jr., and John R. Noble, Co-Personal Representatives - Page 23

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          only evidence which may be considered on the subject” of                    
          valuation.  Id.; accord Polack v. Commissioner, 366 F.3d at 612             
          (“subsequent events that shed light on what a willing buyer would           
          have paid on the date in question are admissible, such as                   
          ‘evidence of actual sales prices received for property after the            
          date [in question], so long as the sale occurred within a                   
          reasonable time ... and no intervening events drastically changed           
          the value of the property.’” (quoting First Natl. Bank v. United            
          States, 763 F.2d 891, 894 (7th Cir. 1985))); see also Estate of             
          Jung v. Commissioner, supra at 431-432; Estate of Scanlan v.                
          Commissioner, supra.                                                        
               Generally speaking, a valuation of property for Federal tax            
          purposes is made as of the valuation date without regard to any             
          event happening after that date.  See Ithaca Trust Co. v. United            
          States, 279 U.S. 151 (1929).  An event occurring after a                    
          valuation date, however, is not necessarily irrelevant to a                 
          determination of fair market value as of that earlier date.  An             
          event occurring after a valuation date may affect the fair market           
          value of property as of the valuation date if the event was                 
          reasonably foreseeable as of that earlier date.  First Natl. Bank           
          v. United States, supra at 894; Bank One Corp. v. Commissioner,             
          120 T.C. at 306.  An event occurring after a valuation date, even           
          if unforeseeable as of the valuation date, also may be probative            
          of the earlier valuation to the extent that it is relevant to               






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