I never heard any rule like that. In my opinion sets are like cards in that one year or one grade is not going to determine value as much as how much care is spent in the selection of the card itself, and eye appeal.
Having built and sold entire graded sets in the past, I can say that much of realizing a set's maximum value is timing, and that is utterly random. What I mean is that any set can have periods of time when there are a few wealthy collectors duking it out, and especially when one such collector (or more) is starting out, that's a great time to sell. Then there are periods where the water just has fewer sharks.
Granted, some sets do have inherent popularity factors like key rookie cards or in the case of 1952, it being Topps' first set. So those sets have a good chance of having shark infested waters, so to speak. But it's key to temper that outlook with the knowledge that a less popular set can have a few avid collectors in it that would make a set seller at the right time realize great value.
Hope that .02 helps.
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