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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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