J. R. Simplot Co. v. Department of Revenue

CARL N. BYERS, Judge.

This matter comes before the court on defendant’s Motion To Dismiss. The underlying facts are:

Plaintiff appealed to the Umatilla County Board of Equalization for the assessment dates of January 1, 1985, and January 1, 1986. After hearings, the board issued its order for 1985 on July 10,1985, and its order for 1986 on July 21,1986. Plaintiff did not appeal from those orders within 30 days, as provided by ORS 305.280(3). Instead, plaintiff waited until November 25, 1987, at which time it petitioned defendant under ORS 306.115 for relief for both years on the basis of “gross…