- 12 - 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, thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011