Scope
Applied fertility only
We value fertility the prior owner applied and that remains, not the native endowment the land always had.
Residual fertility in acquired farmland may represent recoverable basis. AcreBasis measures what remains, establishes its supported value at acquisition, and builds the §167 recovery file for your CPA.
Residual fertility is an unsettled tax position. CSA Partners builds the study and documentation; your CPA or return preparer decides how to use the position.
Tell us about the property. We’ll review the parcel, acquisition and farming history to determine whether an AcreBasis study may be worth pursuing.
Residual fertility in acquired farmland may represent recoverable basis. AcreBasis measures what remains, establishes its supported value at acquisition, and builds the §167 recovery file for your CPA.
Residual fertility is an unsettled tax position. CSA Partners builds the study and documentation; your CPA or return preparer decides how to use the position.
Tell us about the property. We’ll review the parcel, acquisition and farming history to determine whether an AcreBasis study may be worth pursuing.
AcreBasis identifies applied residual fertility that remains after acquisition, separates it from the land’s native endowment, and establishes the evidence needed to support basis and useful life.
Measured. Valued. Substantiated. The study is built under §167, with field evidence mapped to the presence, extent, prior-owner linkage and useful-life requirements described in PLR 9211007.
Every study is built around what was applied, what can be supported at acquisition, and how each nutrient actually exhausts.
Scope
We value fertility the prior owner applied and that remains, not the native endowment the land always had.
Valuation
Basis is established by documented FMV allocation at acquisition, never book value or a flat per-acre headline.
Recovery
Each nutrient depletes on its own measured schedule. Useful life is substantiated, not borrowed from a tax table.
Applied fertility only
Field-wide sampling and baseline modeling isolate residual fertility attributable to prior management from the soil’s native endowment.
Evidenced basis
AcreBasis™ documents an FMV allocation to the measured residual fertility at acquisition. The study does not substitute book value or a flat per-acre assumption.
Per-nutrient useful life
Useful life is built from nutrient behavior, cropping and measured depletion. Follow-up evidence supports the exhaustion period rather than borrowing a generic tax life.
The number comes from the ground, not a table. Each discipline is evidenced before it enters the study.
See the evidence layerPLR 9211007 frames the proof around presence, extent, prior-owner linkage and useful life. AcreBasis answers each element with data.
Field-wide sampling
Dense sampling establishes that residual fertility is present and maps where nutrient levels actually vary across the parcel.
Correct extraction + lab analysis
The proper analytical method measures the extent of residual fertility per nutrient so the study is based on specific quantities rather than inference.
Baseline modeling
Measured levels are compared with the region’s natural or critical baseline to separate prior-management fertility from native soil endowment.
FMV allocation
Quantified fertility is valued by nutrient and constrained by the acquisition allocation so the return position is tied to evidenced basis.
Follow-up depletion evidence
Nutrient-specific drawdown establishes useful life and creates the depletion record that also matters when the property is later disposed of.
AcreBasis addresses residual fertility acquired with the land — not fertilizer you purchased and applied yourself. The study establishes the basis, useful life and supporting evidence for recovery under §167.
The four-part test
The land and its fertility are used in farming.
The fertility is being exhausted on a measurable schedule.
Cost allocated to fertility by FMV at acquisition is documented.
Depletion is measured and evidenced, not assumed.
AcreBasis starts with the acquisition and farming facts before asking you to gather the complete study file.
Purchased property or inherited property with stepped-up basis can establish the basis starting point.
Prior-owner history creates the factual linkage the study needs.
Field-wide sampling must establish the presence and extent of residual nutrients.
Active cropping must draw the nutrients down on a measurable, nutrient-specific schedule.
Recovery by nutrient and documented useful life.
Documented acquisition basis—not book value.
Prepared where an accounting-method change is required.
Sampling, valuation, useful-life evidence and authority in one record.
Recapture is considered from the beginning—not discovered at sale.
CSA Partners
No-Cost Audit Support
A cost segregation study should do more than identify depreciation. It should be built to support the tax position behind it. That is why every CSA Partners study is backed by our audit-support commitment and the CSA Partners Guarantee.
BUT OUR COMMITMENT GOES FURTHER
If a CSA Partners study is audited and a significant depreciation position we identified is ultimately disallowed, we refund the engagement fee.
Applies to the original engagement fee for the study in question and is subject to the terms of the applicable service agreement.
These are the questions landowners ask first. Where the position is unsettled, the answer says so.
Because a regional average is not parcel evidence. Fertility varies by field, crop history, application history and measured excess above the relevant agronomic threshold.
Not automatically. A lookback study adds acquisition-year reconstruction, cropping/input history and depreciation records. Where supportable, the preparer may address the method change through Form 3115 and a §481(a) adjustment.
Prior-owner linkage is one of the core evidentiary requirements. The preliminary reviews the available history and field facts before a full study is recommended.
No. The approved AcreBasis framework treats the acquired measurable component as a capitalized amount under §263(a), with recovery modeled under §167.
No. No Code section, regulation, ruling or case squarely authorizes a buyer’s residual-fertility allocation, and adverse authority is disclosed in the study.
Allocating purchase price to residual fertility reduces basis remaining in land and can affect income recognized on disposition. AcreBasis should be viewed as a timing/conversion strategy, not elimination of tax.
No. CSA Partners builds the study and substantiation file. Your CPA or return preparer decides how to use it and signs/files the return.
We review the property first, then recommend a full study only when the facts support it.
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