Portland General Electric Co. v. Department of Revenue

CARL N. BYERS, Judge.

Plaintiff appeals from defendant’s Opinion and Order No. 84-5566 increasing plaintiffs 1981 corporate tax liability. The appeal concerns two deficiency assessments arising from the same transaction, one for Oregon Corporate Excise Taxes and one for Multnomah County Business Income Taxes.

The facts appear deceptively simple. In 1981, plaintiff received a cash payment from another corporation in exchange for the right to use some of plaintiffs federal tax benefits. The equally simple question is whether that payment is taxable either in part or in full. Some background…