Legal Opinion

Simpson Timber Co. v. Department of Revenue

Oregon Supreme Court

Decided January 29, 1998No. OTC 3651; SC S42599PublishedCited by 21 opinions

1Opinion of the Court

*372FADELEY, J.

Taxpayer is a corporation that engages in the lumber business in many states, including Oregon, Washington, and California. It operates as a single, unitary business.

Under the provisions of ORS 314.605 to 314.670, a fractional portion of taxpayer’s “business income” is taxable in each of the states in which taxpayer conducts its unitary business. ORS 314.610(1) defines “business income” as:

“[lineóme arising from transactions and activity in the regular course of the taxpayer’s trade or business and includes income from tangible and intangible property if the acquisition, the…

2Cases cited11 opinions

  1. Portland General Electric Co. v. Bureau of Labor & IndustriesOregon Supreme Court · 1993
  2. ASARCO Inc. v. Idaho State Tax CommissionSupreme Court of the United States · 1982
  3. FW Woolworth Co. v. Taxation and Revenue Dept. of NMSupreme Court of the United States · 1982
  4. Sperry and Hutchinson Co. v. Department of RevenueOregon Supreme Court · 1974
  5. District of Columbia v. Pierce Associates, Inc.District of Columbia Court of Appeals · 1983

6 more not listed; retrieve them via the Exa API.

3Cited by21 opinions

  1. Polaroid Corp. v. OffermanSupreme Court of North Carolina · 1998
  2. Hoechst Celanese Corp. v. Franchise Tax BoardCalifornia Supreme Court · 2001
  3. Ex Parte Uniroyal Tire Co.Supreme Court of Alabama · 2000
  4. May Department Stores Co. v. Indiana Department of State RevenueIndiana Tax Court · 2001
  5. Gannett Satellite Information Network, Inc. v. STATE, DEPT. OF REV.Montana Supreme Court · 2009

16 more not listed; retrieve them via the Exa API.

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