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  5. 769 P.2d 193 (1989)
 

ALASKA AIRLINES, INC. v. DEPT. OF REV.

OTC 2496/2497; SC S34859, (Control)/SC S34860.

769 P.2d 193 (1989)

307 Or. 406

ALASKA AIRLINES, INC., Appellant, v. DEPARTMENT OF REVENUE, State of Oregon, Respondent. Usair, Inc., Appellant, v. Department of Revenue, State of Oregon, Respondent.

Supreme Court of Oregon.

Argued and Submitted October 6, 1988.

Attorney(s) appearing for the Case

Richard M. Botteri, Portland, argued the cause for appellants. On the brief and reply brief were Robert L. Weiss and James P. Draudt, respectively, and Richard M. Botteri, and Weiss, DesCamp & Botteri, A Professional Corporation, Portland.

Elizabeth S. Stockdale, Asst. Atty. Gen., Salem, argued the cause for respondent. With her on the brief were Dave Frohnmayer, Atty. Gen., Virginia L. Linder, Sol. Gen., and Jerry Bronner, Asst. Atty. Gen., Salem.

Before PETERSON, C.J., LINDE, CAMPBELL, CARSON, JONES, GILLETTE, JJ., and VAN HOOMISSEN, J. Pro Tem.

CARSON, Justice.

Alaska Airlines, Inc. (Alaska), and Pacific Southwest Airlines, Inc. (PSA),1 appeal a decision of the Oregon Tax Court upholding 1986 property tax assessments determined, in part, on the basis of time spent in the air by aircraft that flew over, but did not land in, Oregon.2

In 1986, Alaska and PSA were so-called "regional airlines" qualified to do business in Oregon. Each operated...

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