J. R. Simplot Co. v. Department of Revenue

This case involves the valuation, for ad valorem tax purposes, of a potato processing plant near Hermiston, owned by J. R. Simplot Company (taxpayer), for tax years 1984, 1985, and 1986. The Oregon Tax Court accepted the assessment of the Department of Revenue (department)1 of $46 million for tax year 1984, and $43 million for each of tax years 1985 and 1986. Taxpayer argues that the Tax Court misinterpreted ORS 308.411, which we quote below and which governs the appraisal and valuation of industrial plants.2 We conclude that the Tax Court misconstrued ORS 308.411 and that the…