(petitioner, an international oil pipeline consultant, charged with criminal tax fraud and pled guilty; petitioner also challenged limitations to charitable deduction for artwork donated to charity; court determined that deductions were properly limited by IRS in accordance with I.R.C. Sec. 170(e)(1)(A) to petitioner's basis in the artwork because petitioner did not hold the artwork for more than a year, and signed purchase agreement which petitioner entered into more than a year before donation was merely option to buy and not a contract for purchase because no title passed and artwork not delivered at time agreement entered into and petitioner not obligated to ultimately make purchase under agreement).