Multistate Tax Commission v. Dow Chemical Co.

CARLISLE B. ROBERTS, Judge.

Petitioner, Multistate Tax Commission (MTC), is an agency created by the enactment of 19 states, including the State of Oregon. Pursuant to Article VIII of the Compact which has been adopted by legislatures in all the member states, MTC is granted the authority to make examinations of the records of certain multistate-multinational corporations for tax audit purposes. (Article VIII is a part of Oregon Revised Statutes 305.655.)

The respondent, Dow Chemical Company (Dow), is a foreign corporation conducting business activities within the State of Oregon and within…