Oklahoma Code § 68-2203

Title 68. Revenue And Taxation: Tax not to exceed what ad valorem tax would have been -
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Review by Oklahoma Tax Commission.
It is hereby declared to be the intention of the Legislature
that the tax herein imposed be not greater than the amount of tax
such freight line companies, equipment companies, and mercantile
companies would pay if their cars were taxed on an ad valorem basis,
including any value inuring to such cars by reason of being a part
of a going concern.
The Oklahoma Tax Commission upon the complaint of any person who
claims he is taxed too great a rate hereunder, shall take testimony
to determine whether the taxes herein imposed are greater than the
general ad valorem tax for all purposes would be on such freight
cars, if taxed on an ad valorem basis.  The Commission shall have
the power and it shall be its duty to lower the rate herein imposed
to conform to the facts disclosed at said hearing.
In order to determine the amount of tax such companies would
pay, said Commission may value all cars of any company as a unit and
allocate to Oklahoma that proportion of the total value which the
Oklahoma car mileage bears to the total car mileage of the cars of
any such company during the twelve-month period ending on December
31 of any year, and may then apply to such value so ascertained the
average ad valorem tax rate applied to property throughout the state
for that calendar year.
Added by Laws 1939, p. 417, § 3, emerg. eff. April 15, 1939.
Renumbered from § 805b by Laws 1965, c. 215, § 1.  Amended by Laws
1994, c. 278, § 19, eff. Sept. 1, 1994.

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