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Sperry and Hutchinson Co. v. Department of Revenue

527 P.2d 729, 270 Or. 329 (1974)

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Sperry and Hutchinson Co. v. Department of Revenue

Oregon Supreme Court

527 P.2d 729, 270 Or. 329 (1974)

Facts

The Sperry & Hutchinson Company (Sperry) (plaintiff) was incorporated in New Jersey and domiciled in New York. Sperry’s primary business was selling promotional trading stamps to businesses. Sperry invested its revenue in three categories of investment: short-term securities holding money used in the trading-stamp business, short-term securities held for investment purposes, and long-term securities held for investment purposes. Sperry believed that all the interest it received on its investments was allocable to its domicile, New York, and not apportionable to the other states in which it did business. The Oregon Department of Revenue (the department) (defendant) argued that the interest was apportionable and assessed a tax deficiency against Sperry. The Oregon Tax Court held that the interest from the long-term and short-term securities held for investment purposes was not apportionable, but that the interest from the short-term securities related to the trading-stamp business was apportionable. The department appealed the tax court’s first holding, and Sperry cross-appealed the tax court’s second holding.

Rule of Law

Issue

Holding and Reasoning (O’Connell, C.J.)

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