COLUMBIA MANAGEMENT COMPANY v. Morgan

This is an appeal from a determination by the State Employment Division that plaintiff is an “employer” subject to payment of taxes for unemployment insurance, as required by provisions of the Oregon Employment Division Law (ORS ch 657). The Court of Appeals affirmed that determination. 17 Or App 573, 522 P2d 1396 (1974). We granted plaintiff’s petition for review because of concern arising from the fact that taxes under the same statute and for the same employees have already been paid by another “employer.”

The facts, as found by the referee of the Employment Division, are as follows:

“(1)…