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VAN TRAN v. DEPT. OF REV.

No. OTC 3437; SC S40774.

880 P.2d 924 (1994)

320 Or. 170

Trung VAN TRAN, Appellant, v. DEPARTMENT OF REVENUE, State of Oregon, Respondent.

Supreme Court of Oregon, In Banc.

Decided September 29, 1994.

Reconsideration Denied November 1, 1994.

Attorney(s) appearing for the Case

Clayton C. Patrick, of Patrick & Meadowbrook, Salem, argued the cause and filed the briefs, for appellant.

Jerry Bronner, Asst. Atty. Gen., Salem, argued the cause, for respondent. With him on the brief, was Theodore R. Kulongoski, Atty. Gen., Salem.

GRABER, Justice.

Taxpayer appeals from a judgment of the Tax Court. The relevant facts are not in dispute.1

On August 24, 1990, the Department of Revenue (Department) sent notices of assessment to Taxpayer, adjusting his 1986 and 1987 Oregon individual income tax returns. Taxpayer did not appeal from the notices of assessment to the Department within 90 days of the date of the notices.

Taxpayer paid a portion of the assessed...

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