Excess intangible drilling costs
For purposes of subparagraph (A), the amount of the excess intangible drilling costs arising in the taxable year is the excess of—
(i)#
the intangible drilling and development costs paid or incurred in connection with oil, gas, and geothermal wells (other than costs incurred in drilling a nonproductive well) allowable under section 263(c) or 291(b) for the taxable year, over
(ii)#
the amount which would have been allowable for the taxable year if such costs had been capitalized and straight line recovery of intangibles (as defined in subsection (b)) had been used with respect to such costs.