Appeal of Bockhoff

*562OPINION.

Tkammell: The sole question involved in this appeal is whether the taxpayer shall be allowed a deduction from his gross income for the year 1919, for exhaustion on his one-fifth interest in a pat*563ent acquired by gift as of June 30,1917. Section 214 (a) (8) of the Revenue Act of 1918 provides:

Sec. 214. (a) That in computing net income there shall be allowed as deductions :

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(S) A reasonable allowance for the exhaustion, wear and tear of property used in the trade or business, including a reasonable allowance for obsolescence.

This Board has already held that deductions for…