Koramba Farmers & Graziers No. 1, Dean Phillips, Tax Matters Partner, et al. - Page 12

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          the United States, as defined in sections 7701(a)(9) and (10).              
          Those sections provide:                                                     
                    (9)  United States.--The term "United States" when used           
               in a geographical sense includes only the States and the               
               District of Columbia.                                                  
                    (10)  State.--The term "State" shall be construed to              
               include the District of Columbia, where such construction is           
               necessary to carry out provisions of this title.                       
          The language of the Senate report states that "amounts incurred             
          for improvements that are consistent with a plan of a State                 
          conservation agency are deemed to satisfy the Federal standards."           
          S. Rept. 99-313, supra, 1986-3 C.B. (Vol. 3) at 265 (emphasis               
          added).  There isn't the slightest hint in the legislative                  
          history or the statute itself that Congress had anything else in            
          mind when section 175(c)(3)(A) was enacted.                                 
               Somewhat more plausibly, but nevertheless unconvincingly,              
          the partnerships urge that, even if a "comparable State agency"             
          excludes foreign agencies, section 175(c)(3)(A)(ii) still may be            
          construed so as to permit the partnerships to deduct their                  
          conservation expenditures for the years in issue.  In this                  
          connection, the partnerships contend that their conservation                
          expenditures need only be consistent with the plan of some State            
          agency to be deductible.  Insofar as the New South Wales plan               
          applicable to the area where the Koramba farmland is located may            
          be equivalent to the plan of an agency of any one of the States             
          of the United States or the District of Columbia, the                       





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