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KORAMBA FARMERS & GRAZIERS NO. 1 v. C.I.R.S.

Nos. 98-1454, 98-1460, 98-1461 and 98-1462.

177 F.3d 14 (1999)

KORAMBA FARMERS & GRAZIERS NO. 1; Dean Phillips, Tax Matters Partner, Appellants, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Appellee. Koramba Farmers & Graziers No. 1; Dean Phillips, Tax Matters Partner, Appellants, v. Commissioner of Internal Revenue Service, Appellee. Koramba Farmers & Graziers No. 2; Dean Phillips, Tax Matters Partner, Appellants, v. Commissioner of Internal Revenue Service, Appellee. Koramba Farmers & Graziers No. 2; Dean Phillips, Tax Matters Partner, Appellants, v. Commissioner of Internal Revenue Service, Appellee.

United States Court of Appeals, District of Columbia Circuit.

Decided June 4, 1999.

Attorney(s) appearing for the Case

John R. Wilson argued the cause for the appellants. Peter J. Perla was on brief for the appellants.

Paula K. Speck, Attorney, United States Department of Justice, argued the cause for the appellee. Loretta C. Argrett, Assistant Attorney General, and Richard Farber, Attorney, United States Department of Justice, were on brief for the appellee. Teresa T. Milton, Attorney, United States Department of Justice, entered an appearance.

Before: SILBERMAN, WILLIAMS and HENDERSON, Circuit Judges.

Opinion for the court filed by Circuit Judge HENDERSON.

KAREN LeCRAFT HENDERSON, Circuit Judge:

The appellants, Australian partnerships subject to U.S. income reporting and their tax partner, seek review of a Tax Court opinion holding that they were not entitled to deduct expenditures for water and soil conservation expenditures made for property located in Australia. See Koramba Farmers & Graziers No. 1 v. Commissioner, 110 T.C....

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