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partnerships argue that they have satisfied the requirements of
section 175(c)(3)(A)(ii).
We disagree. For section 175(a) to apply, we believe the
statute requires that the improved land must lie within the State
whose agency is comparable to the SCS, and, as discussed above,
that the "State" referred to by the statute means one of the
States and the District of Columbia which together compose the
United States. The structure of section 175(c)(3)(A), which
expressly refers in clause (i) to "the area in which the land is
located", by obvious implication engrafts the quoted words from
clause (i) onto the end of clause (ii). Statutes "are to be
considered, each in its entirety and not as if each of its
provisions was independent and unaffected by the others."
Alexander v. Cosden Pipe Line Co., 290 U.S. 484, 496 (1934);
accord Union Carbide Corp. & Subs. v. Commissioner, 110 T.C. ___,
___ (1998). It defies logic to suggest that Congress intended to
approve the deduction of conservation expenditures in Nevada, for
example, which are consistent with a conservation plan of an
agency of some other State. The partnerships acknowledge as much
on brief in the domestic context, and we see no reason why the
site-specific requirement should be waived so as to permit
deductions for improved land located in a foreign country, in
this case Australia.
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