NHUSS Trust, et al. - Page 5

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          Donation of Van                                                             
               In October of 1996, petitioners purchased a 1996 Ford E150             
          conversion van.  On October 30, 2000, petitioners donated the van           
          to the Cancer Fund.  At the time of the donation, the van had               
          been used in petitioners’ furniture business and had                        
          approximately 220,000 miles on it,3 and the van had, among other            
          things, a cracked windshield and a broken fender.                           
               At the time of the donation, the Kelley Bluebook indicated             
          generally a wholesale value of $14,750 and a retail value of                
          $20,425 for a van of the same year, make, and model.                        
               On November 10, 2000, Mr. Monte Sobrero appraised the van at           
          $19,750.                                                                    
               The record does not reflect who hired Mr. Sobrero, how much            
          Mr. Sobrero was paid, or who paid Mr. Sobrero for his appraisal.            
          The record is also unclear as to whether the van was still in               
          petitioners’ possession at the time of its appraisal by                     
          Mr. Sobrero.                                                                
               Mr. Sobrero’s stated appraisal qualifications include 40               
          years as a craftsman in metal finishing and paint restoration, 30           
          years as a licensed automotive dealer in California, 15 years as            
          owner-operator of an automotive shop, 10 years as owner-manager             


               3  Petitioner testified that the van was driven between                
          55,000 and 60,000 miles a year in petitioners’ furniture                    
          business.  On their 2000 joint Federal income tax return,                   
          petitioners indicated that in 2000 petitioners drove the van                
          72,000 miles.                                                               




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