Union Pacific Railroad v. Department of Revenue

*13GILLETTE, J.

This ad valorem tax case is before us on appeals by both the taxpayer Union Pacific Railroad (UP) and the Department of Revenue (the Department) from ajudgment of the Oregon Tax Court setting the value of UP’s Oregon property for the 1983 and 1984 tax years at $125,860,000 and $171,360,000, respectively. Union Pacific Railroad v. Dept. of Rev., 11 OTR 165 (1989). On de novo review,1 we modify the decision of the Tax Court in the particulars stated below.

UP is a rail transportation common carrier engaged in interstate commerce and regulated by the Interstate Commerce Commission…