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Oregon Tax Court upholds subscriber-based sourcing rules for non-broadcasting receipts

The Oregon Tax Court has held that an out-of-state cable television service provider was required to apportion all of its revenue by using an audience or subscriber factor in accordance with the state’s broadcaster apportionment statutes, instead of using a cost of performance (COP) methodology generally available to corporate taxpayers. The Tax Court summarily rejected the taxpayer’s argument to use COP based on a plain reading of the statutes and legislative intent.