Historically, expenditures to improve the productivity of soil have been viewed as capital in nature and not deductible. Over the past four decades Congress has acted to make some expenditures deductible if specified conditions are met.
Harl, Neil E.
Agricultural Law Digest: Vol. 1
, Article 1.
Available at: http://lib.dr.iastate.edu/aglawdigest/vol1/iss6/1