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

                                   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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