J. Clark Akers, Iii, Eleanor M. Akers, William B. Akers, and Jo Ann Akers v. Commissioner of Internal Revenue

DAVID A. NELSON, Circuit Judge.

The question presented in these consolidated appeals is whether the Tax Court erred in its determination of the fair market value of certain wastewater treatment equipment donated to Vanderbilt University by William B. Akers and his brother, J. Clark Akers, III. In a memorandum opinion reported at ¶ 84,207 P-H Memo TC (1984), 1 the Tax Court held that the equip ment had a fair market value of $75,000. We consider the Tax Court’s valuation clearly erroneous.

I

The equipment in question consists of two “pilot” wastewater treatment plants mounted on conventional…