(petitioners transferred to county more than 65 acres of undeveloped land for $1,550,000 in part-gift/part-sale transaction; land value reported at $2,950,000 and charitable contributions claimed; IRS rejected charitable deductions on basis that I.R.C. Sec. 170 requirements not satisfied; expert testimony involved issues of development rights, environmental legislation and appraisal methodology that used a statistical model involving polynomial regression analysis to correlate relationship between number of lots undeveloped parcel can be subdivided into and per lot selling price; court gave guidance as to proper role of expert witness in court and then rejected each witness' conclusion due to errors in analysis and application; court reconstructed FMV on its own; thus, appraisal attached to Form 8832 was flawed, but was excused due to reasonable cause; no penalty imposed and partial charitable deduction allowed).