Sec. 179 - Tangible Property

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Hey,
I had a discussion with my professor about tangible property for sec. 179, but wanted to get a 2nd opinion on the issue, possibly with Rev. Rul., Reg. or any kind of an authority for that matter to backup your reasoning. The issue is classification of Nut-Bearing Trees planted by a Manufacturing company, MACRS 15years. I believe it is a tangible real property, while my instructor is convinced it is tangible personal property.

Among few Rev. Rul. 67-51, 1967-1 CB 68 -- IRC Sec(s). 179 - this one seemed to fit my case.

Any input is appreciated! Thanks.
 

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