- 16 - mining the first layer of ore, but it also allows eventual access to lower layers of ore. See Rev. Rul. 86-83, supra. On the other hand, the costs incurred in removing overburden in connection with a strip mine typically are integrally related to extraction of a limited area of the ore or mineral to be mined and, for that reason, are included among the costs of producing a particular increment of the ore or mineral. See Rev. Rul. 77-308, supra; Rev. Rul. 67-169, supra. Before 1983, development expenditures could be deducted under section 616(a) without limitation. Beginning in 1983, the current deduction of development expenditures under section 616(a) in the case of a corporation became subject to the special rules of section 291(b). As first enacted, section 291(b) provided in pertinent part as follows: SEC. 291(b). Special Rules for Treatment of Intangible Drilling Costs and Mineral Exploration and Development Costs.–-For purposes of this subtitle, in the case of a corporation-- (1) In general.-–The amount allowable as a deduction for any taxable year (determined without regard to this section) -- * * * * * * * (B) under section 616(a) or 617, shall be reduced by 15 percent.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011