Department of Revenue v. Soo Lines, Inc.

This appeal from the district court, Lewis and Clark County, involves the validity of the Montana Department of Revenue’s method of assessment of taxes on the Montana property of an interstate railroad. The state tax appeal board (STAB) and the district court held the method of assessment used by the Department of Revenue (DOR) invalid, and assessed respondent Soo Lines, Inc. Montana property at its salvage value. We reverse.

Soo Lines is a Minnesota corporation engaged in railroad operations in seven mid-western states, including Montana. In Montana, Soo Lines owns and operates a spur line…