Legal Opinion
Pennzoil Co. v. Department of Revenue
Oregon Tax Court
Decided March 17, 2000No. TC 4301PublishedCited by 2 opinions
1Opinion of the Court
CARL N. BYERS, Judge.
Pennzoil and its subsidiary corporations (collectively referred to as Pennzoil) appeal from an assessment of additional corporate excise taxes for the 1988 tax year. That assessment arose out of a very large tort settlement received by Pennzoil. Defendant Department of Revenue (the department) contends that the settlement proceeds constitute apportionable unitary business income. The parties stipulated to some facts, and a trial was held to receive evidence with regard to others.
FACTS
Although Pennzoil is a century-old Pennsylvania oil company name, it is a Delaware…
2Cases cited16 opinions
- Portland General Electric Co. v. Bureau of Labor & IndustriesOregon Supreme Court · 1993
- Container Corp. of America v. Franchise Tax BoardSupreme Court of the United States · 1983
- Northwestern States Portland Cement Co. v. MinnesotaSupreme Court of the United States · 1959
- Mobil Oil Corp. v. Commissioner of Taxes of Vt.Supreme Court of the United States · 1980
- Hort v. CommissionerSupreme Court of the United States · 1941
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3Cited by2 opinions
- Pennzoil Co. v. Department of RevenueOregon Supreme Court · 2001
- Department of Revenue v. Terrace Tower U.S.A., Inc.Oregon Tax Court · 2000