Equitable Savings & Loan Ass'n v. Department of Revenue

This is an appeal from a decree of the Oregon Tax Court.① Defendant Department of Revenue appeals from that portion of the decree allowing the deduction of plaintiff’s payments to the Federal Savings and Loan Insurance Corporation’s (FSLIC) Secondary Reserve Account in 1967-1969 as an ordinary and necessary business expense. (ORS 317.255). Plaintiff taxpayer cross-appeals from that portion of the decree refusing to declare invalid defendant’s 1970 regulation amending the apportionment formula for the determination of the income of a multi-state financial institution attributable to Oregon.

*459The…