City of Seattle v. Dept. of Rev.
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Appellants were 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). Each taxpayer owned an interest in electrical transmission capacity that was purchased from the Bonneville
Power Administration (BPA) and was used for transmitting electricity over the Northwest's federally-administered power transmission grid. Together, the taxpayers appealed the grant of summary judgment in which the OregonTax Court, citing "Power Resources Cooperative v. Dept. of Rev.," (996 P2d 969 (2000)), concluded that taxpayers' interest in electrical transmission capacity could (because much of that grid was located in Oregon) be taxed by the department as a property interest "held" by taxpayers, under ORS 307.060. On appeal, taxpayers argued that: (1) "Power Resources" was wrongly decided; (2) the Oregon Supreme Court's decision in "Pacificorp Power Marketing v. Dept. of Rev.," (131 P3d 725 (2006)) did not apply in this case; and (3) the Oregon legislature's repeal of the 2005 property tax exemption benefitting out-of-state power-generating municipalities was enacted in violation of Article IV, section 18, of the Oregon Constitution, a provision that required bills for raising revenue originate in the House of Representatives. The Oregon Court rejected the taxpayers' arguments and affirmed the Oregon Tax Court.
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