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.

Practitioners have raised a question about the handling of trades involving automobiles used for both business and personal use under the listed property rules. The IRS position is detailed in IRS Pub. 917, "Business Use of a Car" (Rev. Nov. 1988). The following examples illustrate both the IRS approach and another approach (keep in mind that examining agents are more likely to look for adherence to the IRS approach).