City of Seattle v. Department of Revenue

*721BALDWIN, J.

In this appeal from the Oregon Tax Court, appellants are three municipal corporations located in Washington State: the City of Seattle, the City of Tacoma, and Public Utility District No. 1 of Snohomish County (taxpayers). Respondent is the Oregon Department of Revenue (department). Each taxpayer owns an interest in electrical transmission capacity that was purchased from the Bonneville Power Administration (BPA) and is used for transmitting electricity over the Northwest’s federally-administered power transmission grid. Together, they appeal from a summary judgment ruling in which…