Allied Timber Co. v. Department of Revenue

CARLISLE B. ROBERTS, Judge.

Plaintiff appeals from the department’s Order No. VL 81-945 (dated August 3,1981). After trial * on a prior order, No. VL 80-167 (April 11, 1980), and remand by the Oregon Tax Court of the issue of value to the Department of Revenue, the questions of fact have been settled and a question of law remains before the court: Do statutes of limitation preclude the application of the doctrine of recoupment under the facts in this suit?

Plaintiff is an Oregon corporation with its principal place of business in Portland, Oregon. During the tax years 1973-1974 through…