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SOUTHERN PAC. TRANS. v. DEPT. OF REV.

Nos. OTC 1093/SC 28807; OTC 1189/SC 28808; OTC 1282/SC 28809; OTC 1362/SC 28810.

664 P.2d 401 (1983)

295 Or. 47

SOUTHERN PACIFIC TRANSPORTATION COMPANY, Respondent, v. DEPARTMENT OF REVENUE, State of Oregon, Appellant.

Supreme Court of Oregon.

Decided May 24, 1983.

Attorney(s) appearing for the Case

Elizabeth S. Stockdale, Asst. Atty. Gen., Salem, argued the cause for appellant. With her on the briefs was Dave Frohnmayer, Atty. Gen., Salem.

John H. Doran, Portland, argued the cause for respondent. With him on the brief were George L. Kirklin and Spears, Lubersky, Campbell & Bledsoe, Portland.

Before LENT, C.J., and PETERSON, CAMPBELL, CARSON and JONES, JJ.

JONES, Justice.

Oregon's statute for assessing the property of designated utilities permits valuing the entire property of the business, both within and without the state, as a unit. The sole issue in this case is whether the property of one such utility includes the properties of an out-of-state affiliate. The problem to be resolved is the test for determining the scope of the valuation unit.

Plaintiff Southern Pacific Transportation Company (Southern Pacific...

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