Carolina Light & Power Co. v. Commissioner

*143OPINION.

Seawell:

The petitioner, in 1905, drilled a well on its land at Aiken, S. C., at a cost of $5,396.99. The sole purpose in drilling the well was to obtain water in sufficient quantity to operate an ice plant. The well proved to be a failure, was capped in the same year, and the ice plant project was then abandoned. The petitioner contends that the cost of drilling the well should be added to $2,500, the original cost of the land, in order to ascertain the profit or loss (under section 204 (b) of the Revenue Act of 1926) realized when the land was sold. The drilling of the well should…