Tiffany-Davis Drug Co. v. Department of Revenue

The tax court held that ORS 317.297 enabled plaintiff to claim certain- pre-merger losses sustained by previously existing subsidiary corporations that had been merged into plaintiff. The tax commission had denied the claim and now appeals the tax court decision. The basis of • plaintiff’s claim is set forth in its complaint relative ■ to the merger of one of the corporations: ,

“The operating loss involved was incurred prior to 1963 by Tiffany-Davis #1, Inc., a corporation formed by and at all times a wholly owned subsidiary of plaintiff. Tiffany-Davis #1, Inc., was liquidated in December,…