SERCOMBE, J.
Petitioner is the campaign committee that managed Jim Bernard's bid for election as Clackamas County Commissioner in 2004. It seeks review of an order of the Secretary of State assessing a civil penalty of $11,550 for petitioner's failure to report the value of the use of a large sign structure as a political contribution on its pre-election and post-election contribution and expenditure (C & E) reports for the 2004 primary and general elections....
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