Koramba Farmers & Graziers No. 1, Dean Phillips, Tax Matters Partner, et al. - Page 9

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          been made by the partnerships, postcalendar 1986 conservation               
          expenditures in a foreign country, in this instance Australia, do           
          not qualify under section 175 by reason of section 175(c)(3)(A).            
               As stated previously, section 175(c)(3)(A) was added by the            
          Tax Reform Act of 1986, Pub. L. 99-514, sec. 401(a), 100 Stat.              
          2221, effective for amounts paid or incurred after December 31,             
          1986, in taxable years ending after that date.  Consequently,               
          since the June 30, 1987, taxable year of Koramba No. 1 ended                
          after December 31, 1986, only the last 6 months of its                      
          conservation expenses for that year are subject to section                  
          175(c)(3)(A).                                                               
               With the enactment of section 175(c)(3)(A), section 175 is             
          for the first time arguably site-specific (the partnerships                 
          challenge site-specificity as to section 175(c)(3)(A)(ii)).  The            
          Congressional objective in enacting the 1986 amendment is                   
          cogently articulated in the Senate report:                                  
                    The committee is concerned that certain                           
                    Federal income tax provisions may be                              
                    affecting prudent farming decisions adversely                     
                    under present law.  In particular, the                            
                    committee is concerned that such provisions                       
                    may have contributed to an increase in                            
                    acreage under production, which in turn may                       
                    have encouraged the present-day                                   
                    overproduction of agricultural commodities.                       
                    * * * [S. Rept. 99-313, 1986-3 C.B. (Vol. 3)                      
                    265.]                                                             
               Thus, the focus of the amendment is to discourage                      
          overproduction of agricultural commodities by keying the                    





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