The Tax Court redetermined values for estate and gift tax purposes of a large parcel of more than 2,500 acres of land near Lake Tahoe, California, transferred to an LLC controlled by the transferor's children. The court rejected the appraisals provided by both the taxpayer and the IRS basing the valuation on parts of both appraisals, taking into account a sale that occurred after both the gift and estate tax valuation dates. The court instead chose a value that was higher than the taxpayers reported, but lower than the value determined by the IRS. Although subsequent events normally are not admissible to determine a property's fair market value, the subsequent sale here was close enough in time to be a reasonable indication of value. Key to the court's holding was that the property was limited by numerous environment restrictions on its use and development, which made the value less than the IRS argued. However, accuracy-related penalties were overturned because the taxpayer reasonably relied on competent appraisers, and relied in good faith on their advice.