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HEWLETT-PACKARD v. BENTON CNTY. ASSESSOR

No. (TC4979, TC4980, TC4987; S061456 (Control), S061457, S061458).

356 P.3d 70 (2015)

357 Or. 598

HEWLETT-PACKARD COMPANY, Plaintiff-Respondent, v. BENTON COUNTY ASSESSOR, Defendant, and Department of Revenue, Defendant-Appellant.

Supreme Court of Oregon, En Banc.

Decided August 6, 2015.

Attorney(s) appearing for the Case

Joseph A. Laronge , Assistant Attorney General, Salem, argued the cause and filed the briefs for appellant. With him on the brief was Ellen Rosenblum , Attorney General.

David L. Canary , Garvey Schubert Barer , Portland, argued the cause for the respondent. Cynthia M. Fraser filed the brief for the respondent. With her on the brief was David L. Canary and William K. Kabeiseman.

In this direct appeal from the Oregon Tax Court Regular Division (Tax Court), we must decide whether the Tax Court properly applied administrative rules governing property tax appraisals. Specifically, this case requires us to consider the relationship between two terms defined in the Department of Revenue's administrative rules: "highest...

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