Behring v. Commissioner
United States Tax Court
Deduction -- Expenses -- Conservation Expenditures for Irrigation -- Simultaneous Farming -- Sec. 175, I.R.C. 1954. -- Conservation expenditures are deductible under section 175 where 80 acres, not recently actively farmed, were being farmed by lessees at the same time that work was being done on the 80 acres to water it by irrigation.
1Opinion of the Court
opinion.
Murdoch, Judge:
The Commissioner determined a deficiency of $6,396.23 in the income tax of the petitioner for 1954. The sole issue for decision is whether $6,943.60 expended by the petitioner in 1954 on farmland is deductible under section 175 of the Internal Revenue Code of 1954. The parties have filed a stipulation of facts and the Commissioner has admitted some allegations of the petition. The facts thus stipulated and admitted are adopted as the findings of fact.
The petitioner, hereafter called Eita, filed her Federal income tax return for 1954 on a calendar year cash basis with…
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