Stonebridge Life Insurance v. Department of Revenue
Oregon Tax Court
1Opinion of the Court
HENRY C. BREITHAUPT, Judge.
I. INTRODUCTION
This matter comes before the court on a stipulated record and comprehensive cross-motions for summary judgment.
II. FACTS
During 2003, Stonebridge Life Insurance Company (taxpayer) engaged in the business of providing life, accident, and health insurance coverage. Taxpayer was licensed to do so in all 50 states and the District of Columbia. Taxpayer’s primary business locations were in Pennsylvania, Maryland, and Texas. Taxpayer had no physical operations, employees, telephone listings, or mail drops in Oregon. All of taxpayer’s Oregon insurance…
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