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First, there is no evidence that the charity’s sale of the
vehicle was at arm’s length. For example, the charity could have
sold the vehicle to a needy person for a small amount to further
the charity’s charitable goals. Second, there is no evidence
that the vehicle was in the same condition when the charity sold
it as when petitioners donated it. Certain parts of the vehicle
may have been sold separately, diminishing its value, or the
vehicle may have been in an accident. On the other hand, the
Kelley Blue Book evidence that the vehicle was listed at $1,750
is a reliable indicator of the vehicle’s fair market value at the
time petitioners donated it. After carefully considering the
evidence each side presented, we conclude that the vehicle was
worth $1,750 at the time petitioners donated it, and petitioners
have therefore substantiated their charitable contribution of
property worth $1,750 to Volunteers of America, Inc.
We next turn to petitioners’ claimed contribution of
property worth $650 to Goodwill Industries. Petitioners
introduced a Goodwill/Easter Seals document indicating that they
donated household, clothing, and other items on October 19, 2003,
and that petitioners received no goods or services in exchange.
The receipt does not list the specific items petitioners
contributed. Mr. Farran testified that he added the $650 value
8(...continued)
Act of 2004, Pub. L. 108-357, sec. 884, 118 Stat. 1632.
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