Smith v. Department of Revenue

CARL N. BYERS, Judge.

Plaintiffs appeal the denial of special assessment for their historic building for tax year 1992. The appeal is grounded on claims of statutory construction and estoppel.

Plaintiffs are husband and wife. In February 1991, they purchased a building on Court Street in Salem known as the old Paulus Building. Prior to purchase, plaintiffs contacted the State Historic Preservation Office (SHPO) and indicated an interest in having the property listed as historic property. As plaintiff Carole Smith (Smith) indicated in her testimony, her primary motivation for obtaining a listing…