Department of Revenue v. Faris

In this appeal from a decision of the Oregon Tax Court, taxpayers challenge a notice of deficiency issued by the Department of Revenue (department) as failing to comply with the statutory certification requirement of ORS 305.265(2). Taxpayers assert that the notice was not properly certified because it did not include a hand signature attesting that it was issued in good faith.

ORS 305.265(2) provides that the notice of deficiency shall:

“(a) State the reason for each adjustment;

“(b) Give a reference to the statute, regulation or department ruling upon which the adjustment is based; and

“(c) Be…