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CITY OF SEATTLE v. DEPARTMENT OF REVENUE

(TC-RD 4946, 4957, 4959, 4958) (SC S061813).

357 P.3d 979 (2015)

357 Or. 718

CITY OF SEATTLE, a municipal corporation of the State of Washington, acting by and through its City Light Department, Plaintiff-Appellant, v. DEPARTMENT OF REVENUE, State of Oregon, Defendant-Respondent. Public Utility District No. 1 of Snohomish County, Washington, a municipal corporation of the State of Washington, Plaintiff-Appellant, v. Department of Revenue, State of Oregon, Defendant-Respondent. 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-Appellant, v. Department of Revenue, State of Oregon, Defendant-Respondent.

Supreme Court of Oregon, En Banc.

Decided September 11, 2015.

Attorney(s) appearing for the Case

Gregory A. Chaimov , Davis Wright Tremaine LLP, Portland, and Gregory C. Narver , Assistant City Attorney, Seattle, Washington, argued the cause and filed the briefs for appellants.

Keith L. Kutler , Assistant Attorney General, Salem, argued the cause for respondent. Melisse S. Cunningham , Senior Assistant Attorney General, filed the brief for respondent. With her on the brief was Ellen F. Rosenblum , Attorney General.

In this appeal from the Oregon Tax Court, appellants are three municipal corporations located in Washington State: The City of Seattle, the City of Tacoma, and Public Utility District No. 1 of Snohomish County (taxpayers). Respondent is the Oregon Department of Revenue (department). Each taxpayer owns an interest in electrical transmission...

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