Colorado Code § 34-44-107

Actions of accounting - setoffs. On and after April 13, 1923, in all actions
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for an accounting between tenants in common of any mine, the working tenant shall be allowed
to establish his expenditures and expenses, by way of setoff against the proceeds and profits of
the operation, without being required to show either that the improvements were necessary or
that they enhanced the value of the property.

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