Legal Opinion
Department of Revenue v. Terrace Tower U.S.A., Inc.
Oregon Tax Court
Decided June 15, 2000No. TC 4395Published
1Opinion of the Court
CARL N. BYERS, Judge.
Plaintiff Department of Revenue (the department) appeals from a magistrate decision holding that gains realized by Defendant Terrace Tower U.S.A., Inc. (taxpayer) on certain investments were not apportionable business income. The department claims the investments were held for purposes of acquiring a unitary property and therefore served an operational function. This matter is before the court on stipulated facts and Plaintiffs Motion for Summary Judgment.
FACTS
John Saunders, a citizen and resident of Australia, is the sole owner of J.S. Securities Pty. Ltd. (Securities)…
2Cases cited9 opinions
- Container Corp. of America v. Franchise Tax BoardSupreme Court of the United States · 1983
- Mobil Oil Corp. v. Commissioner of Taxes of Vt.Supreme Court of the United States · 1980
- Miller Brothers Co. v. MarylandSupreme Court of the United States · 1954
- Butler Bros. v. McColgan, Franchise Tax CommissionerSupreme Court of the United States · 1942
- Allied-Signal, Inc. Ex Rel. Bendix Corp. v. Director, Division of TaxationSupreme Court of the United States · 1992
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