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were debited to cash account on the assets side of peti­tioner’s ledger and were credited to earned surplus either upon receipt or after having first been assigned to con­tributed surplus. The values of the buildings acquired were set up in a building account on the assets side and were credited to surplus.5 * In every instance the cash received by petitioner from a community group was less than the amount expended by it for the acquisition or construction of the local factory building and equipment. In computing its normal tax net income for the taxable years in controversy petitioner deducted depreciation on the buildings transferred by the community groups and on the full cost of the buildings and equipment acquired or enlarged in the communities from which it had received cash. Petitioner also included the total of $971,031.01 in cash and other property in its equity invested capital. The Commissioner disallowed depreciation deductions with respect to the buildings transferred (in the value of $85,471.56) and the properties acquired with cash to the extent paid to petitioner by the groups (in the value of $885,559.45) .“ In computing the amount of deprecia­tion to be allowed, the Commissioner deducted that por­tion of the cost of the buildings, land and machinery which was paid with such contributed cash or equivalent funds.7 The Commissioner in making such reductions allocated the cash contribution to each item, such as buildings, land if any had been purchased, and machinery 5 Both courts below and the Commissioner have as petitioner asserts, that the receipts of property eaxnpdr ecsasslhy awsesruem endot, tax8 eTdh aes iCnocmommies.sioner' does not deny that such deductions were dis­allowed for the first time in 1043, following the decision in D e tro it E d7i sTohne Cao.m ovu. nCto mtmhuiss siodinsearl,l o3w1e9d Uo.n S .a c9c8o u(n1t9 43o)f. depreciation was y$e22a,r4 7e2n.d6e0d fo1r9 4t3h.e fTishcearl ey ewaars e nnod edde t1e9r4m2i naantdi o$n2 4b,y3 0t7h.e1 0C ofomrm itshse ifoinscearl of a deficiency in petitioner’s normal tax for either year. BROWN SHOE CO. v. COMMISSIONER. 5