(petitioner owned several properties and donated the properties to a charitable remainder trust; petitioner prepared own tax return and failed to include qualified appraisal from independent appraiser (petitioner was qualified appraiser) for properties; IRS disallowed charitable deduction; while IRS conceded that value of properties was higher than what petitioner claimed, entire deduction disallowed for failure to follow applicable regulations requiring appraisal; court upheld IRS complete disallowance of charitable deduction).