(individual taxpayer planted vineyard in 2005 and placed vines in service during 2009; taxpayer capitalized cost of land preparation (but not any non-depreciable land costs), labor, rootstock and planting over three years); when plants became viable in 2009, taxpayer claimed I.R.C. Sec. §179 deduction for costs incurred in planting vineyard; vineyard classified as 10-year MACRS property under I.R.C. §168(e)(3)(D)(ii) and is, therefore, property to which I.R.C. §168 applies; vineyard is “other tangible personal property” under I.R.C. §1245(a)(3)(B)(i) because it is an inherently permanent structure and satisfies the definition of “other tangible property” under Treas. 48-(1)(d) and would be tangible personal property if it is not an inherently permanent structure because it meets definition of tangible personal property under Treas. Reg. §1.48-1(c); thus, vineyard is I.R.C. §1245 property as required by I.R.C. §179(d)(1); Rev. Rul. 67-51 no longer applicable for purposes of I.R.C. §179; vineyard acquired by purchase for use in taxpayer’s trade or business; vineyard meets all requirements to be depreciable under I.R.C. §179).