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  5. 898 P.2d 1333 (1995)
 

FISHER BROADCASTING, INC. v. DEPT. OF REV.

OTC 3290; SC S41134.

898 P.2d 1333 (1995)

321 Or. 341

FISHER BROADCASTING, INC., Appellant, v. DEPARTMENT OF REVENUE, State of Oregon, Respondent.

Supreme Court of Oregon, In Banc.

Decided July 20, 1995.

Attorney(s) appearing for the Case

John R. Faust, Jr., of Schwabe, Williamson & Wyatt, Portland, argued the cause for appellant. With him on the briefs were Roy D. Lambert, Portland, and Timothy L. Austin and James Wm. Johnston, of Graham & Dunn, Seattle, WA.

Marilyn J. Harbur, Asst. Atty. Gen., Salem, argued the cause for respondent. With her on the brief was Theodore R. Kulongoski, Atty. Gen., Salem.

VAN HOOMISSEN, Justice.

Plaintiff Fisher Broadcasting, Inc. (taxpayer), brought this action in the Tax Court to obtain refunds of its Oregon corporate excise tax and Multnomah County business tax for the years 1983 and 1984. The Tax Court entered a judgment sustaining the opinion and order of defendant Department of Revenue (department), which denied the refunds. Fisher Broadcasting, Inc. v. Dept. of Rev., 13 OTR 32, 1994 WL 46914 (1994). We review de novo...

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