- 10 - availability of conservation expenditure deductions to amounts incurred that are consistent with a conservation plan approved by the Soil Conservation Service (SCS) of the Department of Agriculture, and if there is no SCS conservation plan for the area in which the property is located, amounts incurred for improvements that are consistent with a plan of a State conservation agency. S. Rept. 99-313, supra, 1986-3 C.B. (Vol. 3) at 265. Respondent argues that the consequence of the form in which Congress chose to cast section 175(c)(3)(A) requires the disallowance of deductions for conservation expenditures outside the United States. The partnerships, of course, dispute this. The partnerships agree with respondent that their conservation expenditures obviously cannot qualify under section 175(c)(3)(A)(i) because in that provision it is expressly provided that the conservation expenditures must be consistent with an SCS-approved plan for the area in which the land is located. The Department of Agriculture through the SCS would be unlikely, to say the least, to deal with land located outside the United States. The partnerships argue that their conservation expenditures can, however, qualify under section 175(c)(3)(A)(ii). They first maintain that the term "State", as used in clause (ii), should be read expansively so as to embrace governmentalPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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