Leo and Evelyn Trentadue - Page 1

                                   128 T.C. No. 8                                     

                               UNITED STATES TAX COURT                                

                      LEO AND EVELYN TRENTADUE, Petitioners v.                        
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 3510-04.              Filed April 3, 2007.                  

                    Ps depreciated trellising, drip irrigation                        
               systems, and a well as farm machinery or equipment, in                 
               connection with their farming activity of growing wine                 
               grapes.  R determined that such property would have a                  
               longer class life and be depreciable as permanent                      
               improvements to land.                                                  
                    Held:  The trellising was properly classified as                  
               farm machinery or equipment, and the irrigation systems                
               and well should be classified as land improvements.                    

               Philip J. Terry, for petitioners.                                      
               Cathy A. Goodson, H. Clifton Bonney, Jr., and Andrew R.                
          Moore, for respondent.                                                      

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