Hewlett-Packard Co. v. Benton County Assessor

In this direct appeal from the Oregon Tax Court Regular Division (Tax Court), we must decide whether the Tax Court properly applied administrative rules governing property tax appraisals. Specifically, this case requires us to consider the relationship between two terms defined in the Department of Revenue’s administrative rules: “highest and best use” and “value of the loss.” See OAR 150-308.205-(D)(1)(c) (defining highest and best use); OAR 150-308.205-(F)(3)(k) (defining value of the loss). A property’s highest and best use is, among other things, the most profitable use that a potential…