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  5. 872 P.2d 414 (1994)
 

KELLER v. DEPT. OF REV.

OTC 3163, 3164, 3165, 3166, 3194; SC S40156.

872 P.2d 414 (1994)

319 Or. 73

Charles A. KELLER, Appellant, v. DEPARTMENT OF REVENUE, State of Oregon, Respondent. Michael McCASLIN and Elizabeth McCaslin, Appellants, v. DEPARTMENT OF REVENUE, State of Oregon, Respondent. Richard B. KELLER, II, Appellant, v. DEPARTMENT OF REVENUE, State of Oregon, Respondent. Richard B. KELLER and Ruth E. Keller, Appellants, v. DEPARTMENT OF REVENUE, State of Oregon, Respondent. Dennis B. KRANZ, Appellant, v. DEPARTMENT OF REVENUE, State of Oregon, Respondent.

Supreme Court of Oregon.

Decided May 12, 1994.

Attorney(s) appearing for the Case

Franklin G. Dinces of Stoel Rives Boley Jones & Grey, Portland, argued the cause for appellants. On the briefs were Milo E. Ormseth and Peter R. Jarvis.

Robert B. Rocklin, Asst. Atty. Gen., Salem, argued the cause for respondent. With him on the brief were Theodore R. Kulongoski, Atty. Gen., Virginia L. Linder, Sol. Gen., and Jerry Bronner, Asst. Atty. Gen.

Before CARSON, C.J., and GILLETTE, VAN HOOMISSEN, FADELEY, UNIS and DURHAM, JJ.

DURHAM, Justice.

In this appeal from a judgment of the Oregon Tax Court, taxpayers claim that they are entitled to a credit under ORS 316.082(1) for their payment of the Business and Occupation Tax ("B & O tax") levied by the State of Washington. ORS 316.082(1) provides, in part:

"A resident individual shall be allowed a credit against the tax otherwise due under this chapter for the amount of any income tax imposed on the individual * * * for...

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