BROWN, Justice.
Appellee, Jack M. Wolfe, dba Wolfe Drilling Company, is an oil and gas drilling contractor headquartered in Oklahoma. Two units, or rigs, of his drilling equipment were operating in Arkansas in 1965, and appellant, Arkansas Commission of Revenues, assessed a compensating (use) tax against the units. Wolfe paid the assessments under protest. After exhausting his administrative remedy, Wolfe successfully prosecuted this action to recover the assessments...
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