Utah Construction & Mining Co. v. State Tax Commission

The dispute concerns an assessment of the Oregon corporate excise tax for a three-year period. The plaintiff taxpayer is a foreign corporation doing business in Oregon and in other states. The issue is how much of the taxpayer’s income is derived from business done in Oregon.

The taxpayer computed its Oregon income by a segregated accounting method and determined that it had a loss in excess of two million dollars for the three years, and that no tax was due. The Tax Commission computed the taxpayer’s income on Oregon business by the apportionment accounting method. The amount of income so…