JOHN R. BROWN, Chief Judge:
This is a tax case on the problems involved in valuing yachts for charitable deductions. It is not a run-of-the-mill tax claim challenging a taxpayer's deduction on a return. The Government in this case went after a marine surveyor, Norman N. Wolfson, who allegedly overstated the value of seventeen yachts donated to two Florida universities. According to the Government, "[t]he indictment in this case was the first prosecution of its kind...
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