Southern Pacific Transportation Co. v. Department of Revenue

CARL N. BYERS, Judge.

At issue in these appeals is the true cash value of that portion of the plaintiffs railroad system located in Oregon for the assessment years 1980 through 1984. The ad valorem tax is assessed by defendant in accordance with the provisions of ORS 308.515.

Southern Pacific Transportation Company, a Delaware corporation, (SPT) is a wholly owned subsidiary of Southern Pacific Company, a holding company. In addition to the railroad property owned by SPT, it also owns subsidiary railroads, the whole of which comprises a railroad system stretching from the west coast through the…