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U.S. BANCORP AND SUBSIDIARIES v. DEPT. OF REV.

TC 4587.

19 OTR 266 (2007)

U.S. BANCORP AND SUBSIDIARIES, Plaintiffs, v. DEPARTMENT OF REVENUE, Defendant.

Oregon Tax Court Regular Division.

Decision for Plaintiff rendered March 13, 2007.

Attorney(s) appearing for the Case

John F. Neupert, Miller Nash LLP, Portland, argued the cause for Plaintiff (taxpayer).

James C. Wallace, Assistant Attorney General, Department of Justice, Salem, argued the case for Defendant (the department).

HENRY C. BREITHAUPT, Judge.

I. INTRODUCTION

This matter comes before the court on remand from the Oregon Supreme Court, U.S. Bancorp v. Dept. of Rev., 337 Or. 625, 103 P.3d 85 (2004) (Bancorp III), cert den, 546 U.S. 813, 126 S.Ct. 48, 163 L Ed 2d 48 (2005).

In Bancorp III, the Supreme Court affirmed...

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