Standard Insurance v. State Tax Commission

Plaintiff appeals from an order and decree of the circuit court which affirmed an order of defendant subjecting plaintiff to the Oregon corporation excise tax. A recitation of the historical background of the case is necessary to explain the basis of our decision.

Plaintiff was originally organized as a capital stock life insurance company in 1906. In 1929 the legislature adopted an act which permitted such a company to change its form of organization to that of a mutual life insurance company. Plaintiff utilized the right created by the act and immediately changed from a stock company to a…