(plaintiff owned several tracts of real estate and transferred seven tracts to family members; gift tax return filed for transfers; IRS challenged valuation of real estate as reported on Form 709 and increased total value by almost $5 million (later reduced by about $3 million), and increased tax by over $1 million; 75 percent civil fraud penalty imposed under I.R.C. Sec. 6663(a) in amount of $781,000 plus almost $500,000 of interest; plaintiff paid deficiency plus fraud penalty and interest and sued for refund; plaintiff's motion to remove fraud penalty not granted because IRS proved by "clear and convincing evidence" that taxpayer intentionally underpaid taxes; county valuation significantly higher than values plaintiff reported, sales contracts on parcels were at much higher value than what plaintiff reported; valuation at over 10 times the reported value could be interpreted by jury as fraud; plaintiff had written letters to appraiser to set value at specific low numbers).