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 States,2 provoked the Internal 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 if adopted, would represent 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.