Philip Morris, Inc. v. Department of Revenue

CARL N. BYERS, Judge.

Plaintiff is a Virginia corporation which manufactures and sells tobacco products throughout the United States. Defendant determined that plaintiff owed Multnomah County Business Income Taxes (MCBIT) for the years 1976 through 1979. (Opinion and Order No. 85-1127.) Plaintiff contends that it is not liable for such taxes and appeals from defendant’s assessment.

Plaintiff ships its products to its warehouse in Clackamas County. Plaintiff’s customers, wholesale distributors, pick up the products and tobacco tax stamps from the warehouse and take them to their own warehouses.…