EVANS, Circuit Judge (after stating the facts as above).
Petitioner argued that because the patent was not issued until 1918, the only basis for computing its depreciation was its cost, and, as its cost was nothing, the substantial allowances made by the Board of Tax Appeals for depreciation were unauthorized.
Article 167, Regulations 45 of the Treasury Department, reads as follows: "Art. 167. Depreciation of patent or copyright. — In computing...
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