In Re the Appeal of Angle

Lorentz, J.:

This is an appeal by George Angle, d/b/a Frontier Oil Company, from an order of the Sedgwick County District Court affirming the determination of the Board of Tax Appeals that drill bits, casing and cement used in the drilling of an oil well are subject to the payment of a sales tax and are not exempt items under K.S.A. 79-3606(n).

The evidence is essentially undisputed, but a recitation is helpful to understanding the nature of the problem.

George Angle, d/b/a Frontier Oil Company, appellant, is in the business of oil and gas drilling and production in the “Barton Arch” area of…