Oregon Festival of American Music v. Employment Department

The Oregon Festival of American Music (petitioner) seeks judicial review of an order of the Employment Department upholding unemployment tax assessments for each quarter of the years 1998 through 2000. We review the department’s order for substantial evidence and errors of law, ORS 183.482(8)(a), (c), and affirm.

The relevant facts are largely undisputed. Petitioner, a nonprofit entity under section 501(c)(3) of the Internal Revenue Code, organizes music festivals, concerts, workshops, lectures, and music schools. It has a director and administrative staff. During each of the three years in…