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  5. 798 F.2d 894 (1986)
 

AKERS v. C.I.R.

Nos. 84-1838 to 84-1840, 84-1842, 84-1844, 84-1845, 84-1881 and 84-1883 to 84-1885.

798 F.2d 894 (1986)

J. Clark AKERS, III, Eleanor M. Akers, William B. Akers, and Jo Ann Akers, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided August 20, 1986.

Attorney(s) appearing for the Case

Mark H. Westlake, argued, Tune, Entrekin & White, Nashville, Tenn., for petitioners-appellants.

Michael J. Roach, argued, Fred T. Goldberg, Jr., Chief Counsel, Washington, D.C., Glenn L. Archer, Jr., Michael L. Paup, Asst. Atty. Gen., Dept. of Justice, Tax Div., Washington, D.C., Ann Belanger Durney, for respondent-appellee.

Before: JONES and NELSON, Circuit Judges, and EDWARDS, Senior Circuit Judge.

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 equipment

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