(IRS issues nonacquiescence in Patel v. Comr., 138 T.C. No. 23 (2012) where the petitioners, married couple, purchased house with intent to tear it down and construct new house on same property; instead of tearing house down, petitioners donated house to local fire department for fire training exercise in course of which house would be burned down; petitioners obtained demolition permit and completed all necessary requirements, including execution of documents giving fire department right to conduct training exercises and burn the house down; house burned down; petitioners reported charitable contribution of $339,504; court upheld IRS denial of charitable deduction in total ($92,865); petitioners did not donate ownership interest in house to charity, but only right to conduct training exercises (license); Sec. 170 (f)(3) denies charitable deduction for donation and use property regardless of value; donation was of only a partial interest, and donation of partial interest not deductible; accuracy-related penalty not imposed because taxpayers within reasonable cause exception of I.R.C. Sec. 6664(c) based on all the facts and circumstances and uncertain status of law on issue; IRS nonacquiescence notes IRS disagreement with court's conclusion that uncertain state of law is factor supporting finding of reasonable cause and good faith where taxpayer did not investigate status of law and did not obtain professional tax advice; IRS position is that taxpayer cannot act in good faith for purposes of not having accuracy-related penalty apply if taxpayer unaware of state of applicable law and made no reasonable attempt to become aware of state of applicable law).