ESCO Corp. v. Department of Revenue

The main issue in this case is whether this taxpayer’s appeal under the “normal” procedure, see ORS 305.275, to the Department of Revenue (Department) of an alleged overvaluation of property in one tax year was also sufficient to invoke the Department’s supervisory authority to correct erroneous valuations made in earlier years. See ORS 306.115(3). We hold that it was not sufficient and affirm the tax court’s grant of summary judgment to the Department.1

I. FACTS

In conducting our review of the tax court record on summary judgment, ORS 305.445, we view the facts in the light most favorable to…