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CITY OF SEATTLE II v. DEPT. OF REV.

TC 4946 & TC 4957, TC 4958, TC 4959.

21 OTR 269 (2013)

THE CITY OF SEATTLE, a municipal corporation of the State of Washington, acting by and through its City Light Department, Plaintiff, v. DEPARTMENT OF REVENUE, Defendant. CITY OF TACOMA, a municipal corporation of the State of Washington, acting by and through its Department of Public Utilities, Light Division dba Tacoma Power, Plaintiff, v. DEPARTMENT OF REVENUE, Defendant. PUBLIC UTILITY DISTRICT NO. 1 OF SNOHOMISH COUNTY, WASHINGTON, a municipal corporation of the State of Washington, Plaintiff, v. DEPARTMENT OF REVENUE, Defendant.

Tax Court of Oregon, Regular Division.

September 11, 2013.

Attorney(s) appearing for the Case

Gregory A. Chaimov , Davis Wright Tremaine LLP, Portland, and Gregory C. Narver , Assistant City Attorney, Seattle, filed the motion and argued the cause for Plaintiffs (taxpayers).

Melisse S. Cunningham , Senior Assistant Attorney General, Department of Justice, Salem, filed the cross-motion and argued the cause for Defendant (the department).

Decision for Defendant rendered September 11, 2013.

HENRY C. BREITHAUPT, Judge.

I. INTRODUCTION

This matter is before the court on a second set of cross-motions for summary judgment. Oral argument on this matter was held June 25, 2013. Plaintiffs' motion to allow submission of post-hearing statements was denied.

II. FACTS

Plaintiffs (taxpayers) are municipal corporations created under the law of the State of Washington and generally...

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