I would pay top dollar for a car that has a proper service history. Second to that comes cosmetic condition, paint, etc. Typically cars that have led a good life are usually decent in all areas.
I bought a M package 540i 6 speed with less than 200k, some issue and spotty history for $12k. That was almost 3 years ago though, and I really didn't know what I was doing.
My recommendation is that if you are truly serious hold out for a good car that has records, and preferably one sold by an enthusiast like the members on the forum here.