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the United States, as defined in sections 7701(a)(9) and (10).
Those sections provide:
(9) United States.--The term "United States" when used
in a geographical sense includes only the States and the
District of Columbia.
(10) State.--The term "State" shall be construed to
include the District of Columbia, where such construction is
necessary to carry out provisions of this title.
The language of the Senate report states that "amounts incurred
for improvements that are consistent with a plan of a State
conservation agency are deemed to satisfy the Federal standards."
S. Rept. 99-313, supra, 1986-3 C.B. (Vol. 3) at 265 (emphasis
added). There isn't the slightest hint in the legislative
history or the statute itself that Congress had anything else in
mind when section 175(c)(3)(A) was enacted.
Somewhat more plausibly, but nevertheless unconvincingly,
the partnerships urge that, even if a "comparable State agency"
excludes foreign agencies, section 175(c)(3)(A)(ii) still may be
construed so as to permit the partnerships to deduct their
conservation expenditures for the years in issue. In this
connection, the partnerships contend that their conservation
expenditures need only be consistent with the plan of some State
agency to be deductible. Insofar as the New South Wales plan
applicable to the area where the Koramba farmland is located may
be equivalent to the plan of an agency of any one of the States
of the United States or the District of Columbia, the
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