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The National Automobile Dealers Association Large Boat
Appraisal Guide (NADA Guide) and the BUC Guide are boat valuation
guides. The NADA Guide, for May through August 1994, and the BUC
Guide, 64th Edition, for Summer 1994, listed the following value
ranges for a 1967 42-foot Sea Voyager Motor Yacht4 with inboard
gasoline engines and a wooden hull:5
Low Average High
NADA Guide $22,750 $27,000 $31,200
BUC Guide 56,200 -- $61,800
Respondent determined that the fair market value of the boat
at the time of its contribution was $22,125. In 1998, Mr. Miller
sold a 1968 42-foot Chris Craft with a wooden hull, gasoline
engines, and no fly bridge--a make and model similar to the boat-
-for $10,000.
OPINION
Fair Market Value
Section 170(a)(1) provides a deduction for charitable
contributions made to qualified entities during the taxable year.
"If a charitable contribution is made in property other than
money, the amount of the contribution is the fair market value of
the property at the time of the contribution". Sec. 1.170A-
1(c)(1), Income Tax Regs. Fair market value is the price at
4 This boat is comparable to petitioners' boat.
5 The parties presented evidence regarding fair market
value according to both guides only for 1994.
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Last modified: May 25, 2011