Mignot v. Department of Revenue

Plaintiffs-taxpayers appeal from a judgment of the Oregon Tax Court affirming an opinion and order of the Department of Revenue (Department) relating to assessment and collection of taxes, penalties and interest for the tax year 1968. Taxpayers argue that the claim for 1968 is void because of the Department’s failure to issue a notice of assessment as required by ORS 314.410(4). We do not reach that question, because taxpayers failed to exhaust their administrative remedies and the Tax Court had no jurisdiction to hear the case.

Taxpayers, husband and wife, filed joint personal income tax…