Jackson v. Department of Revenue

Plaintiffs-taxpayers failed to appeal to defendant Department of Revenue (Department) from a determination and assessment of additional tax within 90 days from receipt of notice. ORS 305.280(1). Plaintiffs then filed this proceeding in the Oregon Tax Court seeking redetermination of their tax liability. The tax court granted Department’s motion to dismiss for failure to exhaust administrative remedies and entered an appropriate judgment. We affirm.

The record, consisting of the pleadings, supporting affidavits, and transcript of proceedings before the tax court, reveals the following facts.…