Barry John Sergeant and Christine M. Sergeant - Page 4

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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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