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All section references, unless otherwise specified, are to
sections of the Internal Revenue Code in effect for the years in
issue. All Rule references are to the Tax Court Rules of
Practice and Procedure.
By order, these cases were consolidated for trial, briefing,
and opinion. They were submitted fully stipulated.
The sole issue for our consideration is whether the Koramba
partnerships' soil and water conservation expenditures
(conservation expenditures) incurred after December 31, 1986,
with respect to land located outside the United States can
qualify for deductibility under section 175.
Background
Koramba No. 1 was organized as a general partnership under
the laws of Australia. At the time each of the Koramba No. 1
petitions was filed, the partnership had its principal place of
business at Koramba, Boomi, New South Wales, Australia.
Koramba No. 2 was organized as a general partnership under
the laws of Australia. At the time each of the Koramba No. 2
petitions was filed, the partnership had its principal place of
business at Koramba, Boomi, New South Wales, Australia.
At all relevant times, Dean Phillips (Phillips) has been the
tax matters partner of Koramba No. 1 and Koramba No. 2
(partnerships). Phillips' address at the time the petitions were
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