REVERSED.
O'CONNELL, J.
This is an appeal from a decree of the Oregon Tax Court setting aside defendant's order requiring plaintiff to pay the Oregon corporate income tax for the calendar years 1955 through 1960. The following statement of facts is adopted from the opinion of the Oregon Tax Court.
Plaintiff (hereafter referred to as "ART") owns refrigerator cars which it leases to operating railroads. "It is not a public carrier, it issues no bills...
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