PETERSON, Judge.
The plaintiff, Jaka Okorn, appeals a judgment of the Oregon Tax Court affirming an administrative Opinion and Order issued by the defendant, Department of Revenue (the Department). The Department had determined that the plaintiff, who had not filed state tax returns, owed personal income tax for calendar years 1984 through 1986. The Department determined the plaintiff's tax liability according to its best information and belief. ORS 305.265(10).<...
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