(petitioner acquired 34-unit apartment building at auction in late 1980s, financing purchase through HUD which later repeatedly cited petitioner for housing violations and initiated foreclosure action; petitioner paid-off mortgage and operated building another 8 years and then quitclaimed building to charity for nominal amount; charity provided written acknowledgment of gift stating that petitioner received nothing in return; petitioner, however, did not attach acknowledgment to return, and appraisal summary submitted with Form 8283 did not identify appraiser that supported petitioner's claimed value of gift of almost $500,000; charity ultimately sold property to third party for $60,000; earlier appraisal conducted for non-tax purposes and later appraisal deemed deficient as it was based on repairs that didn't occur; IRS also challenged petitioner's ownership of building with court determining that any deduction would pass-through from petitioner's S corporation; court determined that appraisal inadequate insomuch as appraiser not qualified and basis overstated and condition of building misrepresented; appraiser also deemed not qualified; substantial compliance inapplicable and deduction denied).