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BLOCKER DRILLING CANADA, LTD. v. CONRAD

Civ. No. 10588.

354 N.W.2d 912 (1984)

BLOCKER DRILLING CANADA, LTD., Anderson-Myers Drilling Company, Atco Drilling, Inc., Brinkerh-off-Signal, Inc., Burris Drilling Co., Kenai Drilling Co., Inc., Kenting Drilling Co., Ltd., Shelby Drilling, Inc., and Star Drilling Co., Inc., Appellees, v. Kent CONRAD, Tax Commissioner of the State of North Dakota, Appellant.

Supreme Court of North Dakota.

August 17, 1984.

Attorney(s) appearing for the Case

Fleck, Mather, Strutz & Mayer, Bismarck, and Holme, Roberts & Owen, Denver, Colo., for appellees; argued by Warren H. Albrecht, Jr., Bismarck. Appearances by Thomas H. Olson and James D. Butler, Denver, Colo.

Robert W. Wirtz and Carla Smith, Asst. Attys. Gen., Tax Dept., Bismarck, for appellant; argued by Robert W. Wirtz.

PEDERSON, Justice.

We are asked to decide for the first time in this state if the tax commissioner can be estopped from reassessing the use tax liabilities of certain taxpayers. The basic facts of the case are relatively straightforward and undisputed.

The taxpayers are out-of-state corporations who are drilling contractors in the oil and gas business. They engaged the services of Clyde Logan and Rick Logan (hereinafter Logan), tax consultants in Denver, Colorado...

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