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SANTA FE DRILLING COMPANY v. RIDDELL

Civ. No. 272-60-PH.

217 F.Supp. 630 (1963)

SANTA FE DRILLING COMPANY, a a corporation, Plaintiff, v. R. A. RIDDELL, District Director of Internal Revenue, Los Angeles District, Defendant.

United States District Court S. D. California, Central Division

April 19, 1963.

Attorney(s) appearing for the Case

Musick, Peeler & Garrett, Joseph D. Peeler, Stuart T. Peeler, By Stuart T. Peeler, Los Angeles, Cal., for plaintiff.

Francis C. Whelan, U. S. Atty., Walter S. Weiss, Asst. U. S. Atty., Chief, Tax Section, Richard G. Sherman, Asst. U. S. Atty., By Richard G. Sherman, Los Angeles, Cal., for defendant.

TAVARES, District Judge.

At the times material to this action, plaintiff, Santa Fe Drilling Company, a California corporation, was primarily engaged in the business of contract oil well drilling operations in the United States and in foreign countries. It kept its books of account and filed its Federal income tax returns on a calendar year basis.

In July, 1954, pursuant to a contract, plaintiff commenced oil well drilling operations in Australia on a fee basis...

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