John H. Gadon

M&T Bank Corp. and Subs. v. Dept. of Rev. – TC-MD 120816N (Or Tax M Div, 2015)
Partial summary judgment for M&T Bank; REIT dividends includible in M&T Bank’s sales factor denominator

M&T Bank Corp. v. Dept of Rev. – TC-MD 120816N (Or Tax M Div, 2014)
Partial summary judgment for M&T Bank, income and receipts of REIT subsidiary excluded from Oregon consolidated returns, REIT respected as separate entity for tax purposes; Oregon dividend-received deduction for REIT dividends allowed

Oracle Corp. v. Dept. of Rev. – TC-MD 070762C (Or Tax M Div, 2012)
Department of Revenue motion for partial summary judgment denied. Taxpayer not required to report income as business income or non-business income uniformly in each state.

American Honda Motor Co., Inc. v. Dept. of Rev. – 20 Or Tax 404 (Or Tax, 2011)
Motion granted to dismiss Department of Revenue’s appeal due to failure to serve American Honda within time required under Oregon statute

American Honda Motor Co., Inc. v. Dept. of Rev. – TC-MD 060524B (Or Tax M Div, 2011)
Partial summary judgment for American Honda. Interest income on car loans purchased by finance subsidiary and on wholesale loans by finance subsidiary to dealers were not sourced to Oregon

AT&T Corp. v. Dept. of Rev. – 15 OTR 202 (Or Tax, 2000)
Summary judgment for AT&T, gross receipts from treasury function transactions included in sales factor denominator, $3 million income tax refund

Weyerhaeuser Co. v. Dept. of Rev. – TC-MD 980749 (Or Tax M Div, 1999)
Treatment of foreign sales in apportionment factor, settlement, substantial tax refund

WTD Industries, Inc. v. United States (In re WTD Industries, Inc.) Case No. 95-8483 (Bankr WD WA)
Federal income tax; settlement; substantial tax refund

• Represented major national real estate developer before the Revenue Division Appeals Board in 2024 case in appeal of Portland Business License Tax and Multnomah County Business Income Tax. The case involved the effect of a tiered partnership’s IRC Section 743 election on local income taxes, where local taxes are imposed on partnerships at the entity level and interplay between (i) federal and Oregon income tax law, and (ii) local income tax law, with respect to the determination of partnership income; favorable settlement.