Brenner v. Department of Revenue

CARLISLE B. ROBERTS, Senior Judge.

The plaintiff appealed from the defendant’s Order No. I 82-25, increasing plaintiffs taxable Oregon personal income for each of the tax years 1976, 1977 and 1978, based upon an indirect methods audit. Three issues are before the court. The plaintiff alleges that:(1) The defendant’s “Second Notice of Assessment,” dated December 31, 1980, for each tax year, was beyond the statutory three-year period of assessment, as described in ORS 314.410, for the tax year 1976 (PI Comp, ¶ XIII);(2) The Department of Revenue hearing officer relied upon information submitted…