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of fact. INDOPCO, Inc. v. Commissioner, supra at 86; Norwest
Corp. v. Commissioner, supra at 280. The distinctions between
current expenses and capital expenditures "are those of degree
and not of kind". INDOPCO, Inc. v. Commissioner, supra at 86
(quoting Welch v. Helvering, 290 U.S. 111, 114 (1933)). "Courts
have adopted a practical case-by-case approach in applying the
principles of capitalization and deductibility." Norwest Corp.
v. Commissioner, supra at 280.3 In this context, we see no need
for us to cut through the thicket of the decided cases and
detail, as the parties have sought to do, their facts and
holdings in order to arrive at a decision herein.4 Rather, we
shall discuss the facts as reflected in the record before us and
arrive at a conclusion, recognizing that we shall be engaging in
an exercise in line drawing, a difficult task which nevertheless
is part of the daily grist of judicial life. See Harrison v.
Schaffner, 312 U.S. 579, 583 (1941); Russell Box Co. v.
Commissioner, 208 F.2d 452, 454 (1st Cir. 1953); Allen v.
Commissioner, 66 T.C. 340, 346 (1976).
The parties have stipulated: (1) The relocation was
accomplished in order to permit the use of the pipeline in the
3 See also 1 Bittker and Lokken, Federal Taxation of
Income, Estates and Gifts, sec. 20.4.8, at 20-92 (2d ed. 1989).
4 As the Supreme Court has observed, the cases in this area
"appear difficult to harmonize". See INDOPCO, Inc. v.
Commissioner, 503 U.S. 79, 86 (1992).
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