Klamath Production Credit Assoc. v. State Tax Commission

Edward H. Howell, Judge.

This is an appeal by plaintiff from the tax commission’s order denying a claim for refund of excise taxes for the years 1959, 1960 and 1961.

It has been stipulated that plaintiff is a unitary corporation doing business in the State of California and entitled to apportion its income under ORS 314.280 and Reg 314.280(1)-(B). The latter allows financial institutions to apportion their income using a three-factor formula of gross payroll, loans and interest. The issue involves the allocation of these factors between Oregon and California.

The Klamath Production Credit…