United States Board of Tax Appeals June 19, 1925, Docket No. 2201 (Appeal of Service Recorder Co.)

*99OPINION.

Smith:

In its appeal the taxpayer alleges error on the part of the Commissioner in disallowing any amount for exhaustion of patents as a deduction from gross income in its tax return for 1919, and also in reducing its claimed invested capital for each of the years 1919 and 1920 by the total amount claimed as the cost to it of the patent license and intangibles.