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  5. 862 P.2d 1288 (1993)
 

DEPT. OF REV. v. UNIVERSAL FOODS CORP.

OTC 2944, 2945; SC S39692.

862 P.2d 1288 (1993)

318 Or. 78

DEPARTMENT OF REVENUE, State of Oregon, Respondent, v. UNIVERSAL FOODS CORPORATION, Appellant. DEPARTMENT OF REVENUE, State of Oregon, Respondent, v. UNIVERSAL FROZEN FOODS CO., Appellant.

Supreme Court of Oregon, In Banc.

Decided December 2, 1993.

Attorney(s) appearing for the Case

John Paul Graff, of Graff & O'Neil, Portland, argued the cause for appellants. With him on the brief was Richard W. Miller, of Duffy, Kekel, Jensen & Bernard, Portland.

Marilyn J. Harbur, Asst. Atty. Gen., Salem, argued the cause for respondent. With her on the brief was Theodore R. Kulongoski, Atty. Gen., Salem.

FADELEY, Justice.

This case involves the authority of the Oregon Department of Revenue (the Department) to issue an administrative subpoena for the purpose of investigating facts related to the Department's duties.

In March 1990, a subpoena was issued under ORS 305.190(1). The administrator of the property tax division of the Department signed the subpoena as the official issuing it. It was entitled in the name of the Department of Revenue, was addressed to...

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