Union Pacific Railroad v. State Tax Commission

Peter M. Gunnar, Judge.

These three cases are suits to set aside defendant’s opinions and orders assessing additional corporation excise tax against plaintiffs for the years 1955 through 1958 and for refund of such tax paid under protest. To each complaint, defendant demurred generally. Because the demurrers present the same issue, the cases were consolidated for hearing, briefing, and decision. The parties agree that a determination of the demurrers will dispose of each case.

The sole issue is whether plaintiffs must include in their apportionable income subject to allocation in part to Oregon…