Publication 535
taxmap/pubs/p535-031.htm#en_us_publink1000208895You can deduct costs paid or incurred during the tax year for
developing a mine or any other natural deposit (other than an oil or gas well)
located in the United States. These costs must be paid or incurred after the
discovery of ores or minerals in commercially marketable quantities. Development
costs include those incurred for you by a contractor. Also, development costs
include depreciation on improvements used in the development of ores or
minerals. They do not include costs for the acquisition or improvement of
depreciable property.
Instead of deducting development costs in the year paid or incurred,
you can elect to treat them as deferred expenses and deduct them ratably as the
units of produced ores or minerals benefited by the expenses are sold. This
election applies each tax year to expenses paid or incurred in that year. Once
made, the election is binding for the year and cannot be revoked for any reason.
taxmap/pubs/p535-031.htm#en_us_publink1000208896The election to deduct development costs ratably as the ores
or minerals are sold must be made for each mine or other natural deposit by a
clear indication on your return or by a statement filed with the IRS office
where you file your return. Generally, you must make the election by the due
date of the return (including extensions). However, if you timely filed your
return for the year without making the election, you can still make the election
by filing an amended return within 6 months of the due date of the return
(excluding extensions). Clearly indicate the election on your amended return and
write "Filed pursuant to section 301.9100-2." File the amended return at the
same address you filed the original return.
taxmap/pubs/p535-031.htm#en_us_publink1000208897The rules discussed earlier for foreign exploration costs apply
to foreign development costs.
taxmap/pubs/p535-031.htm#en_us_publink1000208898The rules discussed earlier for reduced corporate deductions
for exploration costs also apply to corporate deductions for development costs.