Atlantic Richfield Co. v. Department of Revenue

In our previous opinion, Atlantic Richfield Co. v. Dept. of Rev., 300 Or 637, 717 P2d 613 (1986), we held that intangible drilling and development costs (IDCs) should be included in the property factor for the purpose of apportioning income to Oregon. ORS 314.605 to 314.670. The Oregon Department of Revenue has petitioned for reconsideration.

The department makes two claims of error in our previous opinion. The first is that we erred in concluding that a majority of states adhering to the Uniform Division of Income for Tax Purposes Act (UDITPA) required or permitted intangible drilling and…