MRI Diagnostic Services Co. v. Department of Revenue

CARL N. BYERS, Judge.

This matter is before the court on cross motions for summary judgment. The sole issue is whether the Multnomah County Business Income Tax (MCBIT) ordinance treats a partnership as a taxable entity or as a conduit for the partners.

Plaintiff is a partnership composed of two partners: Good Samaritan Hospital and Medical Center and Health Systems Group. Both organizations are exempt from federal and state income taxes under IRC § 501(c)(3). The partnership conducts its business in Multnomah County. Defendant assessed MCBIT for 1988 and denied a refund of MCBIT for 1987 on the…