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LEVEL 3 COMMUNICATIONS v. DEPT. OF REVENUE

(SC S067283).

490 P.3d 149 (2021)

368 Or. 303

LEVEL 3 COMMUNICATIONS, LLC, Plaintiff-Appellant, v. DEPARTMENT OF REVENUE, State of Oregon, Defendant-Respondent.

Supreme Court of Oregon.

July 1, 2021.

Attorney(s) appearing for the Case

Cynthia M. Fraser , Foster Garvey PC, Portland, argued the cause and filed the briefs for appellant. Also on the briefs was Daniel L. Keppler .

Marilyn J. Harbur , Assistant Attorney General, Salem, argued the cause and filed the brief for respondent. Also on the brief were Ellen F. Rosenblum , Attorney General, Benjamin Gutman , Solicitor General, and Jordan R. Silk , Assistant Attorney General.

Per A. Ramfjord , Stoel Rives LLP, Portland, filed the brief of amicus curiae Council on State Taxation. Also on the brief was Nikki E. Dobay , Tax Counsel, Council on State Taxation.

Before Walters, Chief Justice, and Balmer, Nakamoto, Duncan, Nelson, and Garrett, Justices, and Kistler, Senior Judge, Justice pro tempore.

On appeal from the judgment of the Oregon Tax Court, taxpayer Level 3 Communications, LLC (Level 3), a centrally assessed communication company, challenges the Tax Court's determination of the real market value of its tangible and intangible property for the 2014-15, 2015-16, and 2016-17 tax years.1 Level...

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