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tation is in harmony with broad congressional policy as to depreciation deductions was emphasized by the Third Circuit when considering the similar situation presented in Commissioner v. McKay Products Corp., supra, 178 F. 2d at 643: . . the assets received . . . are being used by the taxpayer in the operation of its business. They will in time wear out, and if [the taxpayer] is to con­tinue in business, the physical plant must eventually be replaced. Looking as they do toward business continuity, the Internal Revenue Code’s depreciation provisions—and especially those which provide for a substituted rather than a cost basis—would seem to envision allowance of a depreciation deduction in situations like this. . . .” The Commissioner contends, however, that this con­clusion was foreclosed by Detroit Edison Co. v. Com­missioner, 319 U. S. 98 (1943). That decision denied inclusion in the base for depreciation of electric power lines the amount of payments received by the electric company for construction, of the line extensions to the premises of applicants for service. It was held that to the extent of such payments the electric lines did not have cost to the taxpayer, and that such payments were neither gifts nor contributions to the taxpayer’s capital. We do not consider that case controlling on the issue whether contributions to capital are involved here. Because in the Detroit Edison case “The payments were to the cus­tomer the price of the service,” the Court concluded that “it overtaxes imagination to regard the farmers and other customers who furnished these funds as makers either of donations or contributions to the Company.” Since in this case there are neither customers nor payments for service, we may infer a different purpose in the transactions be­tween petitioner and the community groups. The con- 8 BROWN SHOE CO. v, COMMISSIONER.