*823OPINION.
: We must approve the action of the Commissioner in disallowing the claimed deduction, not on the ground that the taxpayer is precluded from changing its method of reporting the kind of expenditures which give rise to the deficiency, but for the reason that expenditures made for the development and in the acquisition of patents are properly capital expenditures. Appeal of Gilliam Manufacturing Co., 1 B. T. A. 967; Appeal of Goodell-Pratt Co., 3 B. T. A. 30.