Atlantic Richfield Co. v. Department of Revenue

SAMUEL B. STEWART, Judge.

The plaintiff appealed defendant’s Opinion and Order No. I 83-53, determining that intangible drilling costs (hereinafter IDCs) should be excluded from the calculation of the property apportionment factor used to determine the plaintiffs corporate excise tax. On March 24, 1984, the plaintiff moved for an order granting summary judgment in favor of the plaintiff on the grounds that there was no genuine issue as to any material fact. On April 13,1984, the defendant moved for summary judgment in favor of the defendant on the same grounds.

ORS 314.604 to 314.670 is cited…