(petitioner donated conservation easement in accordance with negotiations with local zoning board and in return for county approval of subdivision exemption; IRS denied charitable deduction because donation involved quid pro quo; 20 percent substantial understatement penalty imposed; court noted lack of testimony from practitioner that prepared return; 40 percent gross valuation penalty of I.R.C. Sec. 6662(h)(2) rejected - petitioner's appraisal was from qualified appraiser and was a qualified appraisal and utilized "before and after" approach to valuation).