Legal Opinion
Terrace Tower U.S.A., Inc. v. Department of Revenue
Oregon Tax Court
Decided March 16, 1999No. TC-MD 970100Published
1Opinion of the Court
JILL A. TANNER, Magistrate.
Plaintiff appeals from Defendant’s determination that the capital gain realized from Plaintiffs redemption of capital units of the Encino Split Unit Trust was business income. The issue has been submitted to the court on Cross Motions for Summary Judgment.
FACTS
The parties have stipulated to the following facts. Plaintiff, Terrace Tower U.S.A., Inc. (TT USA), is a Delaware corporation, which as of the end of its fiscal year, June 30, 1994, had not done business in Oregon. TT USA’s wholly owned domestic subsidiary, Terrace Tower U.S.A. - Portland, Inc. (TT USA PDX),…
2Cases cited13 opinions
- Portland General Electric Co. v. Bureau of Labor & IndustriesOregon Supreme Court · 1993
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Container Corp. of America v. Franchise Tax BoardSupreme Court of the United States · 1983
- Allied-Signal, Inc. Ex Rel. Bendix Corp. v. Director, Division of TaxationSupreme Court of the United States · 1992
- ASARCO Inc. v. Idaho State Tax CommissionSupreme Court of the United States · 1982
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