U. S. Bancorp v. Department of Revenue

CARLISLE B. ROBERTS, Senior Judge.

The plaintiff appealed from the defendant’s determination that additional tax assessments are due for tax years 1974 and 1975. The plaintiff alleged that Eurocom Data, Ltd. (“Eurocom”), was properly included in the plaintiffs combined returns for 1974 and 1975 Oregon excise tax because Eurocom and the plaintiff were engaged in a unitary business. In addition, the plaintiff contended that certain additions to the bad debt reserve of Commerce Mortgage Company (“Commerce”), a wholly owned subsidiary, were reasonable and should have been allowed as a deduction on…