Legal Opinion
Pennzoil Co. v. Department of Revenue
Oregon Supreme Court
Decided October 4, 2001No. OTC 4301; SC S47561PublishedCited by 6 opinions
1Opinion of the CourtDe Muniz, J.
The issue in this tax case is whether proceeds that taxpayer Pennzoil Company (Pennzoil) received in settlement of a tort judgment constitute business income under Oregon’s tax code and, if so, whether apportionment of that income is constitutionally permissible. The Tax Court held that the proceeds were apportionable business income. Pennzoil Co. v. Dept. of Rev., 15 OTR 101 (2000). For the reasons that follow, we affirm.
The facts are drawn from the parties’ stipulations and the Tax Court’s findings. In January 1984, Pennzoil agreed to purchase 3/7 of Getty Oil (Getty) stock. In return,…
2Cases cited12 opinions
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Mobil Oil Corp. v. Commissioner of Taxes of Vt.Supreme Court of the United States · 1980
- Miller Brothers Co. v. MarylandSupreme Court of the United States · 1954
- Hans Rees' Sons, Inc. v. North Carolina Ex Rel. MaxwellSupreme Court of the United States · 1931
- Allied-Signal, Inc. Ex Rel. Bendix Corp. v. Director, Division of TaxationSupreme Court of the United States · 1992
7 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Mandell v. Auditing Division of Utah State Tax CommissionUtah Supreme Court · 2008
- Mead Corp. v. Department of RevenueAppellate Court of Illinois · 2007
- Crystal Communications, Inc. v. Dept. of Revenue, Tc 4769 (or.tax 7-19-2010)Oregon Tax Court · 2010
- Mead Corp. v. Department of RevenueAppellate Court of Illinois · 2007
- Pennzoil Co. v. Oregon Department of RevenueSupreme Court of the United States · 2002
1 more not listed; retrieve them via the Exa API.