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COMMISSIONER OF INT. REV. v. ROWAN DRILLING CO.

Nos. 10187, 10236.

130 F.2d 62 (1942)

COMMISSIONER OF INTERNAL REVENUE v. ROWAN DRILLING CO. ROWAN DRILLING CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

Rehearing Denied October 9, 1942.

Attorney(s) appearing for the Case

Warren F. Wattles, Sewall Key, and J. Louis Monarch, Sp. Assts. to the Atty. Gen., Samuel O. Clark, Jr., Asst. Atty. Gen., and J. P. Wenchel, Chief Counsel, and Charles E. Lowery, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for Commissioner of Internal Revenue.

Harry C. Weeks, of Fort Worth, Tex., for Rowan Drilling Co.

Before SIBLEY, HUTCHESON, and HOLMES, Circuit Judges.

HOLMES, Circuit Judge.

The taxpayer and the Commissioner by separate petitions seek a review of the Board's decision, which involves income tax liabilities for the calendar year 1932.1 The petition of the taxpayer presents the question whether a corporation, engaged in the business of drilling oil wells for hire, may deduct from its gross income as ordinary and necessary business expenses, all costs incurred by it during said year in the...

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