Legal Opinion
U.S. Bancorp v. Department of Revenue
Oregon Tax Court
Decided September 19, 2001No. TC 4531PublishedCited by 4 opinions
1Opinion of the Court
CARL N. BYERS, Senior Judge.
Plaintiff (taxpayer) appeals the assessment of additional corporate excise taxes for 1984 through 1992. The additional taxes are attributable to Defendant Department of Revenue (the department) including intangible personal property in the property factor of the apportionment formula. Taxpayer moves for partial summary judgment on the ground that as a matter of law, the department has no authority to include intangibles. The court has considered the written and oral arguments of the parties.
FACTS
Taxpayer is a unitary financial organization doing business in Oregon…
2Cases cited6 opinions
- Portland General Electric Co. v. Bureau of Labor & IndustriesOregon Supreme Court · 1993
- Fisher Broadcasting, Inc. v. Department of RevenueOregon Supreme Court · 1995
- Edward Hines Lumber Co. v. GallowayOregon Supreme Court · 1944
- Equitable Savings & Loan Ass'n v. State Tax CommissionOregon Supreme Court · 1968
- Equitable Savings & Loan Ass'n v. Department of RevenueOregon Tax Court · 1974
1 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- U.S. Bancorp v. Department of RevenueOregon Supreme Court · 2004
- U.S. Bancorp & Subsidiaries v. Department of RevenueOregon Tax Court · 2003
- U.S. Bancorp v. Dept. of Rev.Oregon Tax Court · 2007
- US Bancorp v. Dept. of Rev., Tc 4531 (or.tax 3-13-2007)Oregon Tax Court · 2007