Pacific Coca-Cola Bottling Co. v. Department of Revenue

In this appeal from the Oregon Tax Court, taxpayer (the parent Coca-Cola Company and its wholly owned subsidiary Pacific Coca-Cola Bottling Company which is now known as “Ore-Cal Coca-Cola Bottling Co.”) 1 seeks a refund of $1,299,446.45 of corporate excise taxes paid to Oregon during the tax years 1967 through 1974. We affirm the Tax Court decision denying the refund.

In 1965, Oregon adopted the Uniform Division of Income for Tax Purposes Act (UDITPA), ORS 314.605 to 314.670. That act prescribes a method, not the tax. The method determines how much of the taxpayer’s combined worldwide 2…