-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 toPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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