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interests in three producing oil wells located in Rooks
County, Kansas, that were connected by pipeline to
petitioner’s Phillipsburg refinery. COPA sold all of the
crude oil it produced to CRA.
Petitioner continued to expand its petroleum-related
activities throughout the 1940's. In 1941, petitioner
purchased a refinery in Scottsbluff, Nebraska, with a
production capacity of 1,500 barrels per day. By the
end of its fiscal year 1943, COPA owned interests in 13
producing oil wells. Petitioner’s management informed its
members that 41 cents of the 84 cents in total savings per
barrel created by its petroleum-related business was
attributable to crude oil production.
On January 1, 1944, CRA purchased the assets of the
National Oil Refining Co. for approximately $3.9 million.
These assets included a refinery located in Coffeyville,
Kansas, approximately 269 producing oil wells, leasehold
interests in more than 8,000 acres of undeveloped land, and
a network of pipelines. By the end of 1944, COPA and CRA
together owned interests in 293 producing wells. In
1945, COPA was merged into CRA which conducted all of
petitioner’s oil exploration and production activities from
the time of the merger until 1970. By the end of 1945, CRA
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