Force v. Department of Revenue, 252 P.3d 306

Estate of Pierson (farm owner) faced Oregon inheritance tax on farm value; Department assessed $26,767 plus penalties and interest.
Oregon linked state inheritance tax to pre-2001 federal estate tax law via ORS 118.010(2) and ORS 118.100(1).
Decedent died January 1, 2003; farm valued at about $1.694 million with IRC 2032A farm exemption claimed in federal return.
IRS later recalculated exemption under pre-2001 law, yielding a zero federal estate tax and zero state death tax credit, but Oregon statutes reference the credit 'allowable' under pre-2001 federal law.
Tax Court granted summary judgment for the Department, holding Oregon tax liability aligned with pre-2001 federal law; plaintiff appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper interpretation of ORS 118.010(2).	Force contends IRS zero credit controls Oregon tax.	Department argues 'allowable' credit is tied to pre-2001 federal law per ORS 118.007 and context.	Oregon tax liability determined by pre-2001 federal law; Department entitled to judgment.
Proper interpretation of ORS 118.100(1) timing.	Tax not due because federal estate tax is not payable under current law.	Timing is fixed to federal tax payable under December 31, 2000 code, per ORS 118.007.	Tax due when federal tax payable under pre-2001 code; IRS audit irrelevant.

PGE v. Bureau of Labor and Industries, 317 Or. 606 (Or. 1993) (statutory interpretation principles for Oregon statutes)
State v. Gaines, 346 Or. 160 (Or. 2009) (interpretation of statutory text in context)
Morris v. Dept. of Rev., 320 Or. 579 (Or. 1995) (federal tax references in state tax statutes)
Tharp v. PSRB, 338 Or. 413 (Or. 2005) (interpretation of undefined terms in statutes)
Stevens v. Czerniak, 336 Or. 392 (Or. 2004) (text should be read in context)
Lane County v. LCDC, 325 Or. 569 (Or. 1997) (contextual statutory construction)
Powers v. Quigley, 345 Or. 432 (Or. 2008) (consistency across related statutory provisions)