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DEPT. OF REV. v. FOOTE

No. TC 4780.

19 OTR 405 (2008)

DEPARTMENT OF REVENUE, Plaintiff, v. Michael J. FOOTE, Defendant.

Oregon Tax Court Regular Division.

March 17, 2008.

Attorney(s) appearing for the Case

Keith L. Kutler, Assistant Attorney General, Department of Justice, Salem, filed the motion and argued the cause for Plaintiff (the department).

Darin S. Christensen, Bullivant Houser Bailey PC, Portland, filed the motion and argued the cause for Defendant (taxpayer).

Decision rendered in part for Defendant and in part for Plaintiff March 17, 2008.

HENRY C. BREITHAUPT, Judge.

I. INTRODUCTION

This matter comes before the court on the motion for summary judgment of Defendant Michael J. Foote (taxpayer) and the Motion for Partial Summary Judgment of Plaintiff Department of Revenue (the department).

II. FACTS

The parties have stipulated to the following facts for purposes of resolving...

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