Ian G. Koblick and Tonya A. Koblick - Page 7

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          There were a total of five beds in the habitat.  The vessel was             
          rechristened “Jules Undersea Lodge” (JUL).                                  
               By the end of 1986, JUL was submerged in a lagoon located in           
          Key Largo, Florida.  JUL had its first overnight guest by 1986.             
          By 1989, the vessel and its related equipment were transferred to           
          Sealodge.                                                                   
               The cost to build a vessel in accordance with the standards            
          of the American Board of Shipping (ABS) and to have the vessel              
          certified by the ABS would be from 25 to 50 percent more than the           
          cost to build the same vessel without ABS certification.                    
          JUL has never been certified by ABS.                                        
               JUL has been subject to a regular maintenance program, but             
          there have been no major renovations to it since 1986.                      
               During the years prior to and following the contribution in            
          dispute, approximately 90 percent of JUL’s usage was as an                  
          undersea hotel.  The remaining use has been as a research                   
          facility.  The operation of JUL as an undersea hotel had net                
          operating losses for the 4 years prior to the charitable                    
          contribution ranging from $5,434 to $21,067.                                
                                       OPINION                                        
               In this valuation dispute, the parties adopt very similar              
          methodologies but use widely different estimates of the elements            
          of the methodologies they apply.  Petitioners’ position presents            
          an internal inconsistency between the estimate of replacement               






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