(conservation easement donation case involving plaintiff, a partnership that acquired undeveloped rural land and granted a conservation easement over portion of property; partnership, as taxpayer, claimed charitable deduction tied to land's value as if it were developed for condominium usage; IRS moved to exclude plaintiff's experts' report as unreliable and irrelevant under Fed. R. Evid. 702 and court held that the standards of reliability and relevance apply in non-jury trials - including the Tax Court - and are subject to discretion of trial court Judge; plaintiff's experts did not apply correct legal standard by not using the before-and-after valuation method, did not value contiguous parcels that the plaintiff owned, and assumed development that was not feasible on the property due to multiple zoning restrictions, wetland rules, population decline in the area and lack of land with development potential; court's opinion of major significance where property valuation based on appraisal at issue - appraisals being used and testimony from appraisers that are offered into evidence must withstand judicial scrutiny under Fed. R. Evid. 702 and as developed by U.S. Supreme Court in Daubert v. Merrell Dow Pharmaceutical, Inc., 509 U.S. 579 (1993)).