Ted is a farmer who operates as a sole proprietor. In 2021, Ted purchased $300,000 of farm items for use in the year 2022. On his joint income tax return with his wife, Emma, the farm claimed a deduction for the $300,000 of unused farm items. Before he was able to use any of the items, Ted died in December 2021.

The items were included in the inventory of Ted's assets per estate tax requirements. On the estate return, the items were listed as having a fair market value equal to purchase price. The farm items passed to Emma and received a step-up basis of $300,000.

After Ted's death, Emma became involved in farming. In 2022, she used all of the farm items she received from Ted's estate to grow crops. Later she sold the crops for $500,000. On her 2022 return, Emma reported the crop proceeds as income, but claimed a deduction of $300,000, representing the unused farm items originally purchased by Ted in 2021.

Question: Provide an argument for allowing the deduction AND denying the deduction of farm items received by Emma from Ted's estate and subsequently used in growing crops. How does the Tax Benefit Rule apply to both scenarios? Please provide any relevant support, such code sections or court cases along with your answer. Thanks!