(petitioner, an LLC taxed as a partnership, granted a conservation easement; IRS reduced charitable contribution from approximately $2.2 million to under $500,000 and then to $0; land at issue acquired with intent to subdivide and develop property along river; case involves battle over valuation approaches; court holds that value of contributed easement is $560,000 with contribution limit of 30% of contribution base; charitable contribution is a partnership item as the contribution was made by the partnership).