(case involves value of historic structure permanent facade easement donated to charity and corresponding charitable deduction; before and after appraisal utilized to value easement at $7.445 million; IRS allowed $1.15 million charitable deduction and assessed 40% penalty for gross misstatement; at Tax Court petitioner’s appraiser used replacement cost and income approach to value easement and determined easement value to be $10 million, and IRS determined easement to have no value; Tax Court utilized comparable sales method to value easement at $1.8 million; on further review by Fifth Circuit noted that Tax Court should have included impact of easement on associated building’s fair market value and whether penalty appropriate based on whether satisfied reasonable cause burden of proof; on remand, Tax Court determined that the easement value (and corresponding deduction overstated by more than 400% and that petitioner failed to establish basis for valuation or properly utilize comparable sale approach; gross valuation misstatement occurred; no reasonable cause exception applicable and accuracy-related penalty imposed).