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ATLANTIC RICHFIELD CO. v. DEPT. OF REV.

TC 2001; SC S30995.

722 P.2d 727 (1986)

301 Or. 242

ATLANTIC RICHFIELD COMPANY, Respondent on reconsideration, v. DEPARTMENT OF REVENUE, Petitioner on reconsideration.

Supreme Court of Oregon, In Banc.

July 1, 1986.

Attorney(s) appearing for the Case

Elizabeth S. Stockdale, Asst. Atty. Gen., and Dave Frohnmayer, Atty. Gen., Salem, filed the petition for reconsideration for respondent.

Henry C. Breithaupt, of Stoel, Rives, Boley, Fraser & Wyse, Portland, filed a response for appellant to the petition for reconsideration.

Eugene F. Corrigan, General Counsel, Boulder, Colorado, filed a brief amicus curiae on behalf of Multistate Tax Com'n.

PETERSON, Chief Justice.

In our previous opinion, Atlantic Richfield Co. v. Dept. of Rev., 300 Or. 637, 717 P.2d 613 (1986), we held that intangible drilling and development costs (IDCs) should be included in the property factor for the purpose of apportioning income to Oregon. ORS 314.605 to 314.670. The Oregon Department of Revenue has petitioned for reconsideration.

The department...

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