Garvey, Schubert & Barer v. Department of Revenue

CARL N. BYERS, Judge.

Plaintiff appeals from deficiencies assessed for Multnomah County business income taxes for the years 1983 through 1985. The parties stipulated the facts, leaving only legal issues to be decided.

Prior to January 1, 1984, plaintiff consisted of three professional corporations practicing law in Oregon, Washington and Washington, D.C. The shareholders of each corporation are the attorneys licensed to practice law in each corporation’s jurisdiction. On January 1, 1984, the attorneys organized plaintiff as a “joint venture” of the three professional corporations.

Plaintiff owns…