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Elsworthy Company operates a number of public golf courses in Florida. This year, Elsworthy constructed six new greens of a type described as modern greens.

Elsworthy Company operates a number of public golf courses in Florida. This year, Elsworthy constructed six new greens of a type described as modern greens. Modern greens contain sophisticated drainage systems that include subsurface drainage tiles and interconnected pipes. These tiles and pipes require replacement about every 20 years. The cost of each modern green was $115,000: $30,000 for each earthmoving, grading, and shaping of the land in preparation for construction and $85,000 for construction of the green itself. What is the correct tax treatment of the total cost of each modern green? Please respond in a letter to the file memorandum format.

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