AFFIRMED.
O'CONNELL, J.
Plaintiff appeals from a decree of the Oregon Tax Court, 2 OTC 355 (1966), sustaining the tax commission's disallowance of the personal property offset claimed by plaintiff against its liability for Oregon corporate excise tax. On January 1, 1961, Oregon personal property taxes were assessed against Columbia River Packers Association, an Oregon corporation, on its inventory. The tax became a lien as of that date. ORS 311.405.
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