Twentieth Century-Fox Film Corp. v. Department of Revenue

SAMUEL B. STEWART, Judge.

Plaintiff is in the business of producing and distributing motion pictures. Its only business activity in Oregon during the subject years was the licensing of motion pictures for exhibition by independent theaters in Oregon. Plaintiffs film assets include positive prints (used to exhibit a movie) and film negatives (developed film exposed when the movie was filmed). Plaintiff filed Oregon corporate excise tax returns for 1975, 1976 and 1977, using the standard three-factor apportionment formula. Defendant’s auditor adjusted the property factor for each of the years…