Delta Air Lines, Inc. v. Dept. of Rev.

Summary

The Oregon Supreme Court held that taxing intangible property of centrally assessed businesses does not violate Oregon's Equal Privileges and Immunities Clause, the federal Equal Protection Clause, or the Oregon Constitution's uniformity provisions. Rational-basis review applies, and the classification is supported by legitimate purposes including revenue generation, administrative efficiency, valuation expertise, fairness among centrally assessed businesses, and resource allocation. The court rejected the Tax Court's requirement that the state first demonstrate “genuine differences” in the property or its use.