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method of valuation used to determine the fair market value, and
the specific basis for the valuation. See sec. 1.170A-3(c)(3),
Income Tax Regs. The appraisal summary shall include, inter
alia, a description of the property in sufficient detail for a
person who is not generally familiar with the type of property to
ascertain that the property that was appraised is the property
that was contributed, a brief summary of the physical condition
of the property, the manner of acquisition, and the cost or other
basis. See sec. 1.170A-13(c)(4), Income Tax Regs.
After the parties’ agreement with respect to the fair market
value of the Winter Haven property, the Court must decide whether
petitioners are entitled to a charitable contribution for the
boat in excess of $500.
Petitioners argue that the fair market value of the boat was
$10,000 at the time that the contribution was made to The
Salvation Army. Petitioners did not obtain an appraisal of the
boat. Although Mr. Stewart testified as to the condition of the
boat, petitioners were unable to offer any other persuasive
evidence to aid in the valuation of the boat. We are not
required to accept a taxpayer’s uncorroborated testimony at face
value. Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).
Regardless, Mr. Stewart’s testimony, which was uncorroborated,
does not sufficiently establish the fair market value of the boat
at the time of the contribution.
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Last modified: May 25, 2011