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Petroleum, and such construction companies as Morrison Knudsen
Corp. and Green Construction Co.
Petitioner had no employment other than the operation of his
drilling business during 1978 through 1981. Over a 3-year
period, 1979 through 1981, petitioner earned approximately
$300,000 in revenues from his drilling business. Because of the
short construction season and long Alaskan winter, petitioner's
revenues were earned during a 1- to 2-month period in each of
those years.
In September 1981, petitioner moved from Alaska to
Stavanger, Norway, to accept employment as a drilling engineer
for Mobil Oil Co. on the North Sea. Petitioner continued to work
overseas as a Mobil employee until May 1985. From 1981 through
1984, petitioner returned to Alaska 4 to 6 weeks each year;
during these visits he worked on his drill rig and corresponded
with potential clients. With the exception of a 1-week rental of
the drill rig in 1982, petitioner received no revenue from De
Boer Drilling Co. while he was employed by Mobil.
The Second Drill Rig
In May 1985, soon after completing his employment with
Mobil, petitioner returned to Alaska. In June 1985, petitioner
purchased at auction, for $50,000, another used drill rig that
had an original list price of $650,000, and the capacity to drill
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