Tran v. Department of Revenue

Taxpayer appeals from a judgment of the Tax Court. The relevant facts are not in dispute.1

On August 24, 1990, the Department of Revenue (Department) sent notices of assessment to taxpayer, adjusting his 1986 and 1987 Oregon individual income tax returns. Taxpayer did not appeal from the notices of assessment to the Department within 90 days of the date of the notices.

Taxpayer paid a portion of the assessed taxes. In January 1992, he filed amended Oregon individual income tax returns for 1986 and 1987. Those amended returns claimed a refund. In February 1992, taxpayer also sent the Department…