In 2015, Jed James began planting a vineyard. The costs of the land preparation, labor, rootstock, and planting were capitalized. The land preparation costs do not include any non-depreciable land costs. In 2020, when the plants became viable, Jed placed the vineyard in service. Jed wants to know whether he can claim a deduction under § 179 on his 2020 income tax return for the 2015 costs for planting the vineyard.

(1) brief recap of the facts, (2) discussion of what the issue is, (3) the conclusion as to what the proper tax treatment is, and (4) the law and analysis supporting the conclusion.

• NOTE: the correct analysis will include a discussion of the general requirements of Code Section 179 and a citation to a Chief Counsel Advice (CCA) that was issued within the last 10 years.