Legal Opinion

Sperry and Hutchinson Co. v. Department of Revenue

Oregon Supreme Court

Decided November 5, 1974PublishedCited by 36 opinions

1Opinion of the CourtO’Connell, C.J.

This is an appeal under ORS 305.425 from a decree of the Oregon Tax Court. Sperry & Hutchinson Co. v. Dept. of Rev., 5 OTR Adv Sh 301 (1973). The question presented is whether income received by plaintiff in the tax years 1961, 1963, 1964 and 1965 as interest on investment securities is apportionable in part to Oregon.

The Sperry & Hutchinson Company (S & H) is incorporated in New Jersey, domiciled in New York, and does business in 48 states including Oregon. S & H’s primary business and the only business conducted in Oregon is the sale of a trading stamp promotional service to retailers.…

2Cases cited1 opinion

  1. Fibreboard Paper Products Corp. v. Franchise Tax BoardCalifornia Court of Appeal · 1968

3Cited by36 opinions

  1. Union Carbide Corp. v. HuddlestonTennessee Supreme Court · 1993
  2. NCR Corp. v. Comptroller of the TreasuryCourt of Appeals of Maryland · 1988
  3. McVean & Barlow, Inc. v. New Mexico Bureau of RevenueNew Mexico Court of Appeals · 1975
  4. Montana Department of Revenue v. American Smelting & Refining Co.Montana Supreme Court · 1977
  5. Holiday Inns, Inc. v. OlsenTennessee Supreme Court · 1985

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