- 6 -
private marine survey firm, Todd & Associates, Inc., dated April
14, 1999. They valued the boat as of December 31, 1994. The
appraisal relies on two "blue books", the BUC Used Boat Price
Guide (BUC), and the N.A.D.A. Large Boat Appraisal Guide (NADA).
Under the BUC, the value of a boat manufactured in 1989 (as was
the case here), would range between $34,700 and $38,600; whereas,
under the NADA, for the same boat, its value would range between
$38,350 and $52,500. Respondent's appraisers concluded that the
boat had a fair market value of $47,960 as of December 31, 1994.
The appraisal report noted the fact that IMS had sold the boat
during January 1995 for $35,000, but the appraisers considered
other additional factors in arriving at their $47,960 conclusion.
Section 170(a)(1) allows a deduction for any charitable
contribution to or for the use of an organization described in
section 170(c), payment of which is made during the taxable year.
Respondent agrees that the donee in this case, IMS, was a
qualified organization under section 170(c). In general, the
amount of a charitable contribution made in property other than
money 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 which the property would change hands
between a willing buyer and a willing seller, neither being under
any compulsion to buy or sell, and both having reasonable
knowledge of relevant facts." Sec. 1.170A-1(c)(2), Income Tax
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011