MOORE, Chief Judge.
Plaintiff is engaged in the business of exploring for gas, and of operating such wells as are found to be productive. During the years from 1924 to 1946, plaintiff followed the practice of charging the cost of drilling wells to capital accounts, and deducting annual depreciation on the tangible cost of such wells and depletion for the intangible costs. So far as the record discloses, no nonproductive well was drilled prior to the year 1946.
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