Cite as: 506 U. S. 546 (1993)
Opinion of the Court
narily considered as having a salvage value. Examples of such items are the costs of the actual materials in those structures which are constructed in the wells and on the property, and the cost of drilling tools, pipe, casing, tubing, tanks, engines, boilers, machines, etc. . . . These are capital items and are returnable through depreciation." Treas. Reg. § 1.612-4(c)(1).5
It is the cost of such capital items as these, to the extent that they have not already been recovered through depreciation, that the Hills would like to add to the bases of their mineral deposit interests for purposes of calculating the amount of their percentage depletion deductions subject to the minimum tax.
III
The taxpayers enter the race with a handicap. As we have noted, see n. 4, supra, § 57(a)(8) defines the "property" with which it is concerned by reference to § 614, which speaks in terms of the adjusted basis of "each separate interest owned by the taxpayer in each mineral deposit." 26 U. S. C. § 614(a) (1976 ed). A regulation defines "mineral deposit" as "minerals in place," Treas. Reg. § 1.611-1(d)(4), while a neighboring regulation defines another term, "mineral enterprise," to include "the mineral deposit or deposits and improvements, if any, used in mining or in the production of oil and gas," Treas. Reg. § 1.611-1(d)(3) (emphasis added). Because these regulatory definitions were well established at the time Congress passed § 57(a)(8), see 25 Fed. Reg. 11796 (1960); Pub. L. 91-172, § 301, 83 Stat. 580, 582, we think it reasonable to assume that Congress relied on the accepted distinction between them in its reference to
5 The regulations also foreclose the option with respect to the cost of "labor, fuel, repairs, hauling, supplies, etc., in connection with the operation of the wells and of other facilities on the property for the production of oil or gas." Treas. Reg. § 1.612-4(c)(2). These costs must be "charged off as expense." Ibid.
553
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