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also acquired Eason Drilling Division (Eason Division) and
Crescent (Crescent Division), both operating divisions of Eason,
and Crescent Pipe & Supply Co. (Crescent), a wholly owned
subsidiary of Eason. Samson depreciated rigs and related
equipment that it acquired through the purchase of Eason and
Crescent.
Eason was organized in the 1950's and was based in Oklahoma
City, Oklahoma. Eason was an independent oil and gas company
that operated as a drilling contractor and had ownership
interests in oil and natural gas properties. In 1977, Eason
became a wholly owned subsidiary of ITT Corp. As of August 31,
1988, Eason owned: (1) Ten drilling rigs with related equipment;
(2) one rig yard located in Oklahoma City, Oklahoma; (3) the
inventory of Crescent Division; (4) assets, equipment, and
improvements to real property relating to the operations of
Eason, Eason Drilling, Crescent Division, and Crescent; (5)
contract rights, including those arising from certain safe harbor
leases; (6) trade receivables from unaffiliated third parties;
(7) capital stock and security interests; and (8) a note
receivable from Speller Oil Corp. to Crescent Division dated
November 27, 1985, due and payable on December 1, 1988. Eason's
10 rigs had been used by an Eason company in drilling operations
before Samson acquired Eason's stock. At the time of its
acquisition, Eason had only one rig drilling a well. After it
completed that well in October 1988, none of the Eason rigs were
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