The stunning defeat of the Internal Revenue Service in Ingram Industries, Inc. & Subs. v. Commissioner1 and the high profile loss in FedEx Corp. v. United States2 provoked the Internal Revenue Service to mount a major regulatory overhaul in an effort to reshape the legal terrain over which both battles were fought,3 The controversy appears to be of only modest concern to farmers and ranchers other than for handling overhauls of engines and transmissions on tractors, combines and trucks but the 160 pages of regulations issued on August 21, 2006,4 had those proposed regulations been adopted, would have represented a significant shift in the rules governing whether those and similar types of expenditures could continue to be deductible or would have to be capitalized. However, those regulations were withdrawn in a hail of controversy on March 10, 2008 and new regulations were proposed.5 Those regulations were in turn withdrawn and a new set of temporary regulations were issued on December 23, 2011.6 The temporary regulations became effective, generally, for taxable years beginning on or after January 1, 2012.7



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