Most common reason is crankcase blowby. On flathead engines, a blown head gasket won't cause any oil inhalation.
Here's another weird reason: people deliberately oiling the filter. I've actually seen this recommended in an old (~1980 vintage) book. I just cleaned up a filter that was soaked with oil from the top; i.e., it could not have been introduced by any flaw other than ignorance. Several days ago when I was a young man, I actually tried this myself. Much amusement was had by everyone but me.