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incurred with respect to land located within an area in the
United States that are consistent with statutorily specified
conservation plans for that area. The unfortunate consequence of
this restricting enactment, from the partnerships' point of view,
is that as of 1987 conservation expenditure deductions related to
foreign farmland are no longer allowed by reason of section
175(c)(3)(A). The partnerships' conservation expenditure
deductions must therefore be disallowed.
To reflect the foregoing,
Decisions will be
entered for respondent.
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Last modified: May 25, 2011