Caterpillar Tractor Co. v. Department of Revenue

This is an appeal from a declaratory judgment of the District Court of the First Judicial District, County of Lewis and Clark, determining that the two-year statute of limitations in section 27-2-211, MCA, applied to the assessment of corporate license tax for corporations which failed to file a return.

Caterpillar Tractor Co., Inc., respondent, appealed to the State Tax Appeal Board (STAB) from a determination made by the Montana Department of Revenue, appellant, in December 1978, that respondent had been doing business in Montana for tax purposes for the years 1959 through 1971. Respondent…