110 T.C. No. 33
UNITED STATES TAX COURT
KORAMBA FARMERS & GRAZIERS NO. 1, DEAN PHILLIPS, TAX MATTERS
PARTNER, ET AL.,1 Petitioners v. COMMISSIONER OF
INTERNAL REVENUE, Respondent
Docket Nos. 3679-96, 3680-96, Filed June 29, 1998.
3681-96, 3682-96.
Partnerships subject to U.S. income reporting
made soil and water conservation expenditures in
connection with their farming operations in New South Wales,
Australia, during the years in issue. Under sec. 175,
I.R.C., R allowed the deduction of such expenditures made by
one of the partnerships during calendar year 1986, but
applying sec. 175(c)(3)(A), I.R.C., denied deductions by
both partnerships of such expenditures made after Dec.
31, 1986. The Tax Reform Act of 1986, Pub. L. 99-514, sec.
401(a), 100 Stat. 2221, added sec. 175(c)(3)(A) to the
1Cases of the following petitioners are consolidated
herewith: Koramba Farmers & Graziers No. 1, Dean Phillips, Tax
Matters Partner, docket No. 3680-96; Koramba Farmers & Graziers
No. 2, Dean Phillips, Tax Matters Partner, docket No. 3681-96;
and Koramba Farmers & Graziers No. 2, Dean Phillips, Tax Matters
Partner, docket No. 3682-96.
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