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establishing the amount that a hypothetical willing buyer would
have paid a hypothetical willing seller for the subject property
as of the valuation date.3 Polack v. Commissioner, supra at 612;
First Natl. Bank v. United States, supra at 893-894; Estate of
Gilford v. Commissioner, 88 T.C. 38, 52-54 (1987); Estate of
Jephson v. Commissioner, 81 T.C. 999, 1002-1003 (1983); Estate of
Scanlan v. Commissioner, supra. Unforeseeable subsequent events
which fall within this latter category include evidence, such as
we have here, “‘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.’” Polack v. Commissioner,
supra at 612 (quoting First Natl. Bank v. United States, supra at
894); First Natl. Bank v. United States, supra at 893-894; see
also Estate of Jung v. Commissioner, supra at 431-432; Estate of
Scanlan v. Commissioner, supra.
3 Subsequent events may be considered as evidence of value
if they are relevant. Federal law favors the admission of
probative evidence, and the test of relevancy under Federal law
is designed to reach that end. Sabatino v. Curtiss Natl. Bank,
415 F.2d 632, 636 (5th Cir. 1969). Fed. R. Evid. 401, a rule
that applies to this Court under Rule 143(a), states broadly that
evidence is “relevant” if it has “any tendency to make the
existence of any fact that is of consequence to the determination
of the action more probable or less probable than it would be
without the evidence.” Fed. R. Evid. 401 favors a finding of
relevance, and only minimal logical relevance is necessary if the
disputed fact’s existence is of consequence to the determination
of the action. Daubert v. Merrell Dow Pharm., Inc., 509 U.S.
579, 587 (1993).
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