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

Summary

The Oregon Supreme Court held that Oregon may tax intangible property of centrally assessed businesses without violating the state’s uniformity provisions, the Oregon Equal Privileges and Immunities Clause, or the federal Equal Protection Clause. Applying deferential rational-basis review, the court concluded that revenue generation, administrative efficiency, valuation expertise, fairness among centrally assessed businesses, and resource-based line drawing supplied rational grounds for the classification. The court reversed the Tax Court and remanded for further proceedings.