Difficult to tell just seeing the picture's ..
In my country TJ's are rare and hard to find ..so a 20 year old "rust " TJ and a +120K miles are still around 14 and 16 K Euro.
That's why the import business/agency around here for US vehicle's are upcoming.
You live in the rusty world. Frame rust is #1. Any new and fresh paint underneath is suspect. Body rust is #2. And unless both are immaculate then the price is high.(for NY)