-23-
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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