Industrial Refrigeration & Equipment Co. v. State Tax Commission

Edward H. Howell, Judge.

The question before the court in this ease is whether the plaintiff is primarily engaged in manufacturing and assembling goods so as to entitle it to offset personal property taxes against the corporate excise tax, ORS 317.070.①

*123The plaintiff corporation is engaged in the business of selling, installing, manufacturing and assembling various kinds of refrigeration equipment.

The defendant upon the trial conceded that the plaintiff is “primarily” engaged in manufacturing and assembling if “primarily” means “substantially.” It does. This court so decided in Guy F. Atkinson…