DeHOOG, J.
ORS 305.437 requires the Oregon Tax Court to impose a "penalty" of up to $5,000 when a taxpayer has taken a "position" in a Tax Court proceeding that "is frivolous or groundless." Taxpayers, who did not dispute that they had in fact been paid substantial wages in tax years 2016-18, nevertheless contended in the Tax Court that they owed...
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