Caterpillar Tractor Co. v. Department of Revenue

CARLISLE B. ROBERTS, Judge.

The plaintiffs appealed from the Department of Revenue’s Order No. I 78-2, dated January 27, 1978. Caterpillar Tractor Co. (hereinafter designated as Caterpillar) was and is engaged primarily in the manufacture of engines and machinery at locations outside the State of Oregon, with sales thereof within the State of Oregon and elsewhere. Towmotor Corporation (hereinafter, Towmotor), during the tax years in question, was a wholly owned subsidiary of Caterpillar and was and is a corporation engaged primarily in the manufacture of engines and machinery at locations both…