ABC Inc. and Combined Affiliates v. Dept. of Rev.

CourtOregon Tax Court
DecidedSeptember 8, 2025
DocketTC 5431
StatusUnpublished

This text of ABC Inc. and Combined Affiliates v. Dept. of Rev. (ABC Inc. and Combined Affiliates v. Dept. of Rev.) is published on Counsel Stack Legal Research, covering Oregon Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
ABC Inc. and Combined Affiliates v. Dept. of Rev., (Or. Super. Ct. 2025).

Opinion

IN THE OREGON TAX COURT REGULAR DIVISION Corporation Excise Tax

ABC INC. AND COMBINED ) AFFILIATES, ) ) Plaintiffs, ) TC 5431 v. ) ) DEPARTMENT OF REVENUE, ) State of Oregon, ) ORDER DENYING DEFENDANT’S ) OBJECTIONS TO PLAINTIFFS’ FORM Defendant. ) OF JUDGMENT

I. INTRODUCTION

As required in net income tax cases, Plaintiffs fully paid the assessed tax, penalty and

interest before the deadline for filing their complaint. See ORS 305.419. 1 After the court

granted Plaintiffs’ motion for partial summary judgment, the parties successfully negotiated a

resolution of their remaining differences stemming from Defendant’s audit, including agreement

on which affiliates engaged in “interstate broadcasting” during the years at issue, and how to

compute the amount of refund owing to Plaintiffs. However, a new issue arose as the parties

attempted to agree on a form of judgment: the parties now are divided over how to interpret

ORS 305.222(1), a statute specific to Defendant that imposes an enhanced rate of interest if

Defendant fails to pay a court-ordered refund within 60 days after entry of judgment. 2 The

References to the Oregon Revised Statutes (ORS) are to the 2023 edition unless otherwise indicated. 1

References to this court’s rules (TCR) are to the 2025 edition. 2 ORS 305.222(1) does not use the term “judgment,” referring instead to the “date of the order,” and the “date the order is entered.” Defendant asserts, and Plaintiffs do not dispute, that the 60-day period is measured from the date of entry of a judgment of this court or an appellate judgment of the Oregon Supreme Court because only a

ORDER DENYING DEFENDANT’S OBJECTIONS TO PLAINTIFFS’ FORM OF JUDGMENT TC 5431 Page 1 of 12 question is which court’s judgment--as between this court and the Oregon Supreme Court if the

case is appealed--starts the running of the 60-day period.

ORS 305.222(1) (emphasis added) provides:

“In the case of a refund of tax ordered by the Oregon Tax Court or the Oregon Supreme Court and arising under any law administered by the Department of Revenue, if the refund is not paid by the department within 60 days after the date of the order, the interest rate provided under ORS 305.220 shall be four percent greater than the annual interest rate provided under ORS 305.220, but only with respect to interest periods that begin 61 days after the date the order is entered.”

Plaintiffs submitted a proposed form of judgment that includes the following provision:

“Post-judgment interest shall be owed on the entire money judgment at the rate established under ORS 305.220 beginning the date this judgment is entered. In addition, the increase in the rate established under ORS 305.220 described in ORS 305.222(1) shall apply to any unpaid portion of the money judgment beginning 61 days after this judgment is entered.”

(Ptfs’ Proposed Form J, May 15, 2025.) Defendant objects on the ground that,

“[c]orrectly read, ORS 305.222(1) prescribes that [enhanced] interest only begins 61 days

after the entry of a final, non-appealable order of either this court (i.e., if no further

appeal to the Supreme Court is filed or available) or of the Supreme Court (if an appeal to

that forum is timely filed).” (Def’s Obj Ptfs’ Form J at 1, ¶ 3.f.) Defendant has

judgment is enforceable. (See Def’s Obj to Ptfs’ Form J at 3.) This court agrees that, as to its own proceedings, the 60-day period in ORS 305.222(1) is measured from entry of a judgment, not from issuance of an earlier order or other expression of the court’s decision, because the judgment is the “concluding and final decision of the court on one or more requests for relief” (TCR 67 A(1)) expressing the “final decision[ ] and final order[ ]” from which a party may appeal to the Supreme Court (ORS 305.445)). Although ORS chapter 18 does not apply to this court, the definition of a judgment in this court’s rules thus closely mirrors the definition for a circuit court in ORS 18.005(8) as “the concluding decision of a court on one or more requests for relief in one or more actions, as reflected in a judgment document.” See ORS 18.025 (ORS chapter 18 applies to “circuit courts, municipal courts and justice courts and to county courts performing judicial functions”). The close match is not accidental, but rather complies with the mandate in ORS 305.425(3) that this court’s rules and procedures “conform, as far as practical to the rules of equity practice and procedure in this state.” And by that token this court’s judgment, upon entry, “[b]ecomes the exclusive statement of the court’s decision in the case” and “[m]ay be enforced * * *.” ORS 18.082(1). This court finds it unnecessary at this stage to parse the meaning of “order” as to any pronouncement of the Supreme Court, nor does the court decide that any order of this court, of any kind or character, must be reduced to judgment before it can be enforced. See, e.g., TCR 78 B (governing contempt proceedings).

ORDER DENYING DEFENDANT’S OBJECTIONS TO PLAINTIFFS’ FORM OF JUDGMENT TC 5431 Page 2 of 12 submitted its own form of judgment that would modify Plaintiffs’ provision by adding

the italicized text shown below:

“Post-judgment interest shall be owed on the entire money judgment at the rate established under ORS 305.220 beginning the date this judgment is entered. In addition, the increase in the rate established under ORS 305.220 described in ORS 305.222(1) shall apply to any unpaid portion of the money judgment beginning the later of 61 days after this judgment is entered, or 61 days after an appellate judgment affirming or modifying this judgment is entered.”

(Id. (italics added by the court).) The parties’ respective forms of judgment do not

otherwise differ materially.

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Bluebook (online)
ABC Inc. and Combined Affiliates v. Dept. of Rev., Counsel Stack Legal Research, https://law.counselstack.com/opinion/abc-inc-and-combined-affiliates-v-dept-of-rev-ortc-2025.