IN THE OREGON TAX COURT MAGISTRATE DIVISION Income Tax JOHN A. CARSON ) and MARLIS C. CARSON, ) ) Plaintiffs, ) TC-MD 150355N (Control) ) v. ) ) DEPARTMENT OF REVENUE, ) State of Oregon, ) ) Defendant. ) ) ) JOHN A. CARSON ) and MARLIS C. CARSON, ) ) Plaintiffs, ) TC-MD 160203N ) v. ) ) DEPARTMENT OF REVENUE, ) State of Oregon, ) ) Defendant. ) FINAL DECISION
The court entered its Decision in the above-entitled matter on October 10, 2016.
Plaintiffs timely filed a Statement for Costs and Disbursements (Statement) on October 21, 2016,
requesting their costs in the amount of $504 for the court filing fees. Defendant timely filed an
Objection to Plaintiffs’ Statement on October 31, 2016. The court’s analysis and determination
of Plaintiffs’ request for costs and disbursements is contained in section III. The court’s Final
Decision otherwise incorporates its Decision without change.
Plaintiffs appeal Defendant’s Notice of Deficiency Assessment, dated April 7, 2015, and
Notice of Assessment dated January 26, 2016, for the 2010 and 2011 tax years, respectively. A
trial was held on June 8, 2016, in the courtroom of the Oregon Tax Court in Salem, Oregon. Ted
FINAL DECISION TC-MD 150355N; 160203N 1 E. Runstein, attorney, appeared on behalf of Plaintiffs. John A. Carson (John) and Marlis C.
Carson (Marlis) testified on behalf of Plaintiffs.1 Nancy Berwick, tax auditor, appeared on
behalf of Defendant. The parties filed Stipulated Facts on June 7, 2016. Plaintiffs’ Exhibit 1 and
Defendant’s Exhibits A through S were received without objection.
I. STATEMENT OF FACTS
Plaintiffs owned two residences during the tax years at issue; one in Lake Oswego,
Oregon and the other in Sun Valley, Idaho. (Stip Facts at ¶¶11-12.) There is no dispute that
Plaintiffs were domiciled in Oregon prior to 2009. (Id. at ¶5.) Marlis testified that, in 2008,
John turned 80 and she had survived cancer; at that point in time they decided to make the move
from Oregon to Idaho. She testified that they planned to make the transition from Oregon to
Idaho in 2009 because 2008 was already half over. Marlis testified that Plaintiffs talked with
their accountant in 2008 about their decision to move to Idaho and they were told that they
needed to be out of Oregon for at least six months plus one day.2 John and Marlis each testified
that, during the tax years at issue, they typically spent summers and winters in Idaho, and springs
and falls in Oregon or elsewhere. They each testified that, during the 2009, 2010, and 2011
years, John kept track of days that Plaintiffs spent in Idaho. (Ptfs’ Ex 1 at 1-3.) Their total
annual days in Idaho were as follows: 226 in 2009; 186 in 2010; and 185 days in 2011. (Id.) No
evidence was presented to indicate how many days Plaintiffs spent in Oregon each year.3
/// 1 When referring to a party in a written decision, it is customary for the court to use the last name. In this case, the court’s Decision references two individuals with the same last name, Carson. To avoid confusion, the court will use the first name of the individual being referenced. 2 Defendant questioned whether Plaintiffs’ residency change was a tax planning tool. Marlis testified in response that income taxes were not a part of the decision. She testified that Sun Valley, Idaho imposes a nine percent sales tax, so the change to Idaho did not result in a big tax advantage. 3 Plaintiffs’ residency questionnaire submitted to Defendant states that Plaintiffs spent “170 or less” days in Oregon in 2009, 2010, and 2011. (Def’s Ex F at 2.)
FINAL DECISION TC-MD 150355N; 160203N 2 For the 2010 and 2011 tax years, Plaintiffs timely filed joint Oregon income tax returns
as full-year nonresidents of Oregon. (Stip Facts at ¶1.) Defendant issued notices of assessment
based on its determination that Plaintiffs did not intend to abandon their Oregon domicile as of
2010 or 2011. (See Def’s Ex D, Conference Decision Ltr at 5.) Plaintiffs assert that they were
domiciled in Idaho, not Oregon, in 2010 and 2011. (Compl at 1.)
A. Plaintiffs’ Oregon Connections
1. Early life and family
John and Marlis were each born in Oregon and were domiciled in Oregon all of their
lives until at least 2008. (See Stip Facts at ¶¶4-5.) John testified that he served in the Navy after
high school and then attended the University of Oregon. He testified that, after attending
university, he joined the Infantry and served during the Korean War. John testified that, after
completing his military service, he returned to Oregon to work. John bought a house in Lake
Oswego in 1969. (Id. at ¶12.) John testified that he and Marlis married in 1970. He testified
that, after Plaintiffs’ marriage, they added a bedroom to the Lake Oswego house for their
children. During the tax years at issue, Plaintiffs maintained “minimal personal effects” in their
Lake Oswego house for use when they visited Oregon. (Id. at ¶12.) John testified that Plaintiffs
have never wanted to sell their Lake Oswego house and may leave it to their children. (See id.)
Plaintiffs have four adult children who each lived in Oregon at least part of the year.
(Stip Facts at ¶20.) Marlis testified that one of Plaintiffs’ daughters lived in California in 2010
and 2011, and she temporarily lived in Plaintiffs’ Lake Oswego house upon her return to Oregon
in 2011. She testified that, as of the date of trial, one of Plaintiffs’ sons lived in Palm Springs,
California, and Plaintiffs periodically visited him there.
///
FINAL DECISION TC-MD 150355N; 160203N 3 2. Business activities
John testified that he purchased an oil company in 1971 that became Carson Oil. (See
also Stip Facts at ¶9.4) John testified that he retired in 2004 and sold Carson Oil to his stepson
on a 10-year payment schedule. (See also id.) He testified that his stepson now runs the
company. Since 2004, John has received a $500 monthly stipend from Carson Oil that is
intended to pay for a portion of his medical expenses. (Id. at ¶10; see also Def’s Ex R.) John
testified that there are gaps in his Medicare coverage for vision and dental, so the stipend is to
supplement Medicare. He testified that the stipend was not paid in return for services rendered
to Carson Oil during the tax years at issue, even though he may on occasion have spoken with
his stepson about the business during that time.
John testified that, as of 2004, he owned three commercial properties in Oregon. He
testified that he eventually sold all three properties to his stepson. According to their 2010 and
2011 Schedules E, Plaintiffs received rental income of $37,200 and $24,800, respectively, from a
commercial property located in Cascade Locks, Oregon. (Def’s Exs K at 16, L at 13.) John and
Marlis were each surprised to learn that they still owned the Cascade Locks property in 2010 and
2011. According to an OLCC News Release, dated November 21, 2011, Plaintiffs were listed as
corporate principals for the Food Mart in Hood River, Oregon. (Def’s Ex Q at 1.) John testified
that he was not a corporate principal of Food Mart in 2011.
3. Community and philanthropic activities
Historically, Plaintiffs were active with Oregon organizations. By 2008, Plaintiffs had
“discontinued long-term financial support to the Oregon Symphony” and “discontinued long-
term personal involvement * * * with Legacy/Good Samaritan Medical Center and the Oregon
4 The Stipulated Facts state that Carson Oil Co., Inc. was established in 1957, but John testified that he purchased it in 1971.
FINAL DECISION TC-MD 150355N; 160203N 4 Environmental Council.” (Stip Facts at ¶¶29-30.) John did not serve as a board member for any
Oregon organizations during the tax years at issue. (Id. at ¶17.)
Plaintiffs continued some philanthropic activities in Oregon during the tax years at issue.
“The John & Marlis Fund was associated with the Oregon Community Foundation during the
[tax] years at issue.” (Stip Facts at ¶19.) Marlis testified that Plaintiffs were required to be
actively involved with the Oregon Community Foundation to direct the use of their donated
funds. Plaintiffs donated less than $100 to the Hoyt Arboretum between April 2015 and March
2016. (Def’s Ex P at 3-4.) Marlis was on the “advisory board” of the Dougy Center, a Portland-
based nonprofit. (Id. at 5.) She testified that everyone who donates is listed on the advisory
board.
John testified that he and Marlis have been involved with the Salvation Army since about
1961. He testified that Oregon and Idaho are in the same Salvation Army region. John testified
that the regional director offered to name a building in Portland after Plaintiffs in recognition of
their generosity and they accepted. (See Def’s Ex P at 6.) He testified that the building is a safe
house for women and children.
Plaintiffs were members of the Multnomah Athletic Club in Portland for 63 years. (Stip
Facts at ¶6.) John testified that Plaintiffs were still members in 2010 and 2011; they terminated
membership in 2015. They “became inactive in the club because of [their] time spent in Idaho.”
(Id.) Plaintiffs attended church in Oregon occasionally. (Id. at ¶8.) John was a member of the
Oregon American Legion during the tax years at issue. (Id. at ¶7.)
4. Other Oregon connections
John relinquished his Oregon driver’s license in February 2009. (Def’s Ex H at 1.)
Marlis relinquished her Oregon driver’s license in March 2011. (Id. at 2.) Marlis testified that
FINAL DECISION TC-MD 150355N; 160203N 5 she waited until her Oregon driver’s license expired before getting an Idaho driver’s license.
Plaintiffs have two cars registered and maintained in Oregon.5 (Stip Facts at ¶16.) John testified
that Plaintiffs typically fly between Oregon and Idaho, so having cars in Oregon is convenient.
Neither John nor Marlis were registered to vote in Oregon during the years at issue. (Id. at ¶14.)
“Professionals handling [Plaintiffs’] financial matters are in Oregon.”6 (Id. at ¶32.) Plaintiffs’
grantor trusts were administered in Oregon. (Id. at ¶21.)
B. Plaintiffs’ Idaho Connections
John testified that he had a tough childhood, but saw the movie Sun Valley Serenade – a
ski movie set in Sun Valley – in high school, which inspired his lifelong dream to live the Sun
Valley lifestyle. He testified that he joined the University of Oregon ski team during college and
traveled to Sun Valley to ski during that time. Marlis testified that John took her to see Sun
Valley Serenade on their second date and he told her about seeing the movie during his youth
and his dream to live there one day. John testified that he always intended make Sun Valley
Plaintiffs’ permanent residence someday.
In 1984, Plaintiffs purchased a condominium unit in Sun Valley. (Stip Facts at ¶11.) In
1997, Plaintiffs sold that condominium and purchased a three-bedroom house in Sun Valley.
(Id.) John testified that Plaintiffs purchased the house because it had no stairs and it was larger
with more bedrooms for visiting family. He testified it was Plaintiffs’ intent at that time to
eventually reside permanently in the Sun Valley house. Plaintiffs had and have a PO Box for a
mailing address in Idaho because the post office will not deliver mail in the area. (Id.)
5 The stipulated facts indicated only one car in Oregon, but John testified that they had two cars. 6 John testified that he did not know of any financial advisors.
FINAL DECISION TC-MD 150355N; 160203N 6 Marlis testified that, although Plaintiffs’ children lived in Oregon, Plaintiffs saw their
family more frequently in Idaho than in Oregon. Plaintiffs’ family tended to visit them for
fishing, golf, and a Jazz Festival during summer, and for skiing in the winter. (Stip Facts at ¶22.)
1. Community and philanthropic activities
John and Marlis each testified that the majority of their friends are in Idaho. Marlis
testified that Plaintiffs are very active in Idaho: they hike with a group and ski every day they
can. Plaintiffs became members of the Sun Valley and Sawtooth Ski Clubs prior to 2000. (Stip
Facts at ¶10.) John was a member of the Idaho American Legion during the years at issue. (Id.
at ¶7.) Marlis testified that Plaintiffs were and are very involved with the Idaho Symphony.
Plaintiffs have been members of “a church in Ketchum, Idaho, since 2002.” (Id. at ¶8.)
Plaintiffs contributed to several Idaho charities and organizations. Plaintiffs “supported
the Sun Valley Symphony since before 2000”; “the Galena Lodge Project, a donation based
recreational area in Idaho”; the Idaho Conservation League; the Sun Valley Center for the Arts
since 2004; the Community Library in Idaho since before 2000; and the St. Luke’s Hospital in
Sun Valley. (Stip Facts at ¶¶23-28.)
2. Other Idaho connections
Plaintiffs have each been registered to vote in Idaho since December 2008. (Stip Facts at
¶14.) Marlis testified that she obtained an Idaho driver’s license when her Oregon license
expired in 2011. Plaintiffs had two vehicles registered in Idaho. (Id. at ¶15.) John and Marlis
each testified that their checking account is in Idaho. Marlis testified that her doctor is in Idaho.
(See also id. at ¶33.) Beginning with tax year 2009, Plaintiffs filed Idaho resident income tax
returns. (Id. at ¶2.) Marlis testified that Idaho considers Plaintiffs to be residents and they
received a resident property tax benefit, which was a “nice surprise.”
FINAL DECISION TC-MD 150355N; 160203N 7 II. ANALYSIS
The issue in this case is whether Plaintiffs were domiciled in Oregon or Idaho during the
2010 and 2011 tax years. “Oregon imposes a tax on the entire taxable income of Oregon
residents—even income earned from sources outside of this state, unless explicitly exempted.”
Hillenga v. Dept. of Rev., 21 OTR 396, 400 (2014), aff’d in part, rev’d in part, 358 Or 178, 361
P3d 598 (2015). Oregon imposes a state income tax on every nonresident with Oregon source
income “that is derived from sources within this state.” ORS 316.037(3).7
A “ ‘resident’ or ‘resident of this state’ means: [a]n individual who is domiciled in this
state * * *.” ORS 316.027(1)(a)(A). “A domicile differs from a residence in that a person may
have many residences, but they can only have one domicile. A person’s domicile remains that
person’s domicile until that person establishes a new domicile at a different location.” Hillenga,
21 OTR at 401 (citations omitted). In order to effect a change in domicile three requirements
must be satisfied: “(1) residence in another place, (2) an intention to abandon the old domicil,
and (3) an intention to acquire a new domicil.” Elwert v. Elwert, 196 Or 256, 265, 248 P2d 874
(1952); see also Davis v. Dept. of Rev., 13 OTR 260, 264 (1995). As the party seeking relief,
Plaintiffs bear the burden of proof by a preponderance of the evidence. ORS 305.427.
There is no dispute that Plaintiffs were domiciled in Oregon prior to 2009. They assert
that they changed their domicile to Idaho in 2009. The first requirement for a change in domicile
is a residence in another place. “Residence” and “place of abode” are synonymous and each
“signifies a building or shelter which is the dwelling place of a person.” Ramsey v. Dept. of Rev.,
7 OTR 478, 481 (1978). Plaintiffs acquired a residence in Idaho in 1984, thereby satisfying the
first requirement for a change in domicile.
7 The court’s references to the Oregon Revised Statutes (ORS) are to 2009.
FINAL DECISION TC-MD 150355N; 160203N 8 “The intent to abandon an old domicile and to acquire a new one must be a present
intent.” Dane v. Dept. of Rev., 21 OTR 15, 22 (2012), citing Oberhettinger v. Dept. of Rev., 4
OTR 62, 64 (1970). “Factors that contribute to determining domicile include family, business
activities and social connections.” OAR 150-316.027(1)(a). “Because the criteria governing
domicile are unavoidably subjective, the court cannot simply rely on the potentially self-serving
testimony of the person or persons concerned; the question must be answered by reference to the
objective circumstances and the overt acts of the person or persons at issue.” Hillenga, 21 OTR
at 401, citing Hudspeth v. Dept. of Rev., 4 OTR 296, 298 (1971).
It is evident from the facts presented that Plaintiffs maintained significant ties to both
Oregon and Idaho during the tax years at issue. Plaintiffs had sufficient means to maintain
houses, cars, and personal possessions in both Oregon and Idaho. Similarly, Plaintiffs
participated in some social and philanthropic activities in both states. Plaintiffs’ adult children
each lived in Oregon at least part-time during the tax years at issue. However, Plaintiffs testified
that they spent more time with their children in Idaho during family vacations. Those facts each
demonstrate ties to both states and are not especially helpful in determining Plaintiffs’ domicile.
Another challenge in determining Plaintiffs’ intent from objective facts is identifying a
notable occurrence in 2008 or 2009 that would support a finding that Plaintiffs changed their
domicile from Oregon to Idaho.8 Plaintiffs have owned residential property in Idaho since 1984
and they purchased their current house in 1997. John retired and sold his primary business,
Carson Oil, in 2004, yet continued to consider himself an Oregon resident after 2004. See, e.g.,
Dane, 21 OTR at 23 (concluding that the taxpayer’s retirement alone was not evidence of his
intent to abandon his Oregon domicile when, five years after his retirement, he continued to
8 Often people move due to a change in their employment or marital status. No such facts are present here.
FINAL DECISION TC-MD 150355N; 160203N 9 spend roughly 40 percent of his time in Oregon). When asked during trial about the significance
of 2008, Marlis testified that John turned 80 in 2008 and she had survived cancer. Those events
were the impetus for Plaintiffs to make the move to Idaho. Given that Plaintiffs already owned a
house in Idaho and they maintained their house in Oregon, the practical effect of their move was
to make Idaho their primary residence and Oregon their secondary residence.
The question is whether Plaintiffs had taken sufficient steps as of the tax years at issue to
abandon their Oregon domicile and acquire an Idaho domicile. As noted above, Plaintiffs were
retired as of the tax years at issue and had few business connections to either state. By 2010,
John had sold all but one of his commercial properties in Oregon. No evidence was presented to
indicate that John spent time in Oregon managing that property. See, e.g., Dane, 21 OTR at 25
(“Taxpayer’s real property holdings in Oregon – and more specifically, the manner of [his]
involvement with taxpayer’s real estate holdings in Oregon – are the deciding factor in this
case.”). Similarly, Plaintiffs’ family connections to each state are inconclusive. Plaintiffs’
children are adults who live on their own. Plaintiffs spend time with their children in both states.
Philanthropy and community involvement have long been important aspects of Plaintiffs’
lives. In years prior to 2008, Plaintiffs were involved with several Oregon organizations both
through financial contributions and as board members. As of 2008, Plaintiffs had ceased some
of those activities in Oregon and redirected their efforts toward several Idaho organizations.
Plaintiffs maintained some involvement with Oregon organizations: they were involved with the
management of a charitable fund in Oregon and donated to a few Oregon organizations. With
respect to their social connections, Plaintiffs spent time engaged in outdoor recreation with
hiking and skiing clubs in Idaho. However, they also maintained their membership in the
Multnomah Athletic Club until 2015.
FINAL DECISION TC-MD 150355N; 160203N 10 After Plaintiffs decided to change their primary residence from Oregon to Idaho, they
relinquished their Oregon driver’s licenses in favor of Idaho licenses, registered to vote in Idaho,
filed Idaho resident income tax returns, and received an Idaho resident “property tax break.”
(Stip Facts at ¶31.) Following a conversation with their accountant in 2008, Plaintiffs tracked
their days in Idaho to ensure that they, in fact, spent more time in Idaho than in Oregon. This
court has, at times, not placed significant weight on those facts, particularly where other facts
clearly overshadow their significance. See, e.g., Hudspeth v. Dept. of Rev., 4 OTR 296, 299
(1971) (finding taxpayer abandoned his Oregon domicile even though he retained his Oregon
voter registration because taxpayer was working full time at a lumber mill in Colorado); Brueske
v. Dept. of Rev., TC-MD 090020D, WL 724425 at *5 (Mar 3, 2010) (finding the taxpayer had
abandoned his Oregon domicile even though he retained his Oregon driver’s license and voter
registration because he lived and worked in Arizona); Smith v. Dept. of Rev., TC-MD 150312N,
WL 2984472 at *7 (May 17, 2016) (finding little probative value in the fact that the taxpayer
retained an Oregon driver’s license where taxpayer worked Washington). However, those “facts
each, at the margins” demonstrate Plaintiffs’ intent. Ashby v. Dept. of Rev., 21 OTR 47, 52
(2012). When the court has placed little weight on those facts, it was because they appeared
insignificant in the wider context of the taxpayer’s life. In this case, Plaintiffs acted purposefully
to change their licenses and registrations and, under the circumstances, those changes were
significant. The court is persuaded that those actions demonstrated Plaintiffs’ sincere intent to
change their domicile to Idaho.
This case presents a close call with respect to Plaintiffs’ domicile given their connections
to both Oregon and Idaho. Plaintiffs’ testimony regarding their dream to live in Sun Valley was
compelling. Ultimately, the court is persuaded that, as of the tax years at issue, Plaintiffs had
FINAL DECISION TC-MD 150355N; 160203N 11 effected a change in their domicile from Oregon to Idaho as part of their long-term plan to retire
in Idaho. Plaintiffs spent the majority of each year in Idaho and took overt actions consistent
with their stated intent, by changing their driver’s licenses and voter registration.
III. COSTS AND DISBURSEMENTS FACTS AND ANALYSIS
Plaintiffs filed a Statement requesting an award of $504 for their filing fees. Defendant
filed an objection to Plaintiffs’ Statement on October 31, 2016. The Magistrate Division has
discretionary authority under ORS 305.490(2) to award costs and disbursements to the prevailing
party. Wihtol I. v. Dept. of Rev., 21 OTR 260, 267–68 (2013); TCR-MD9 16. Although TCR-
MD 16 does not define “prevailing party,” this court has looked to the definition of “prevailing
party” found in ORS 20.077(2), regarding making an award of attorney fees, for guidance. Stade
v. Dept. of Rev., TC-MD 150369N, WL 282206 at *5 (Jan 21, 2016). ORS 20.077(2) defines the
prevailing party as “the party who receives a favorable judgment or arbitration award on the
claim.” Thus, the court must determine the prevailing party on a “claim-by-claim basis,”
weighing “what was sought by each party against the result obtained.” Stade, 2016 WL 282206
at *5 (citations and internal quotation marks omitted).
In this case, Plaintiffs challenged Defendant’s Notices of Assessment based on its
determination that Plaintiffs were domiciled in Oregon. The court concluded that Plaintiffs were
domiciled in Idaho, rather than Oregon. Plaintiffs are, therefore, the prevailing party.
The next question is whether the court should exercise its discretion to award costs and
disbursements to Plaintiffs. This court has previously identified several considerations relevant
to its decision to award costs, including whether the originally filed return was accurate, whether
the taxpayer availed himself of any administrative appeal available to him, and “whether the
9 Tax Court Rule-Magistrate Division
FINAL DECISION TC-MD 150355N; 160203N 12 outcome on appeal involved wins and losses for both parties.” Stade, 2016 WL 282206 at *5;
see also Wihtol v. Multnomah County Assessor, TC-MD 120762N, WL 274126 at *5 (Jan 24,
2014).
Defendant gave a few reasons in support of its opposition to Plaintiffs’ request for costs.
First, Defendant asserted that it had an “expectation of prevailing in court” because the
“conference officer was very thorough in his review of the documentation and in allowing
additional time for the Plaintiff’s representatives to provide additional evidence and then writing
a long and carefully considered conference decision in favor of the Defendant.” (Def’s
Objection at 1.) Second, Defendant argued that Plaintiffs caused Defendant confusion regarding
the status of trial in the Magistrate Division and, as a result, Defendant was not adequately
prepared for trial. (Id.) Specifically, Plaintiffs filed a petition for special designation less than
30 days before the scheduled June 8, 2016, trial date, causing the case to be held pending the
outcome of that petition. (Id.) Third, Defendant noted that the court relied in part on calendars
that had not been provided during the audit or conference and “only came to light during the
trial.” (Id. at 12.)
The court is skeptical that Defendant would have reached a different determination had it
been provided Plaintiffs’ calendar during the audit or conference. However, the court recognizes
that Defendant did not receive that piece of evidence prior to this appeal, and as a result, a
different outcome might have been possible. As stated above, this case presented a close call.
Domicile determinations are fact-specific, and reasonable minds can reach different conclusions
viewing the same or similar sets of facts. Defendant made a reasoned determination based on the
evidence it had received. For those reasons, the court finds a cost award is not appropriate in this
case.
FINAL DECISION TC-MD 150355N; 160203N 13 IV. CONCLUSION
After careful consideration, the court finds that Plaintiffs have demonstrated by a
preponderance of the evidence that they were domiciled in Idaho rather than Oregon during the
2010 and 2011 tax years. The court further finds Plaintiffs’ request for costs and disbursements
should be denied. Now, therefore,
IT IS THE DECISION OF THIS COURT that Plaintiffs’ appeal is granted.
IT IS FURTHER DECIDED that Plaintiffs’ request for costs and disbursements is
denied.
Dated this day of November 2016.
ALLISON R. BOOMER MAGISTRATE
If you want to appeal this Final Decision, file a Complaint in the Regular Division of the Oregon Tax Court, by mailing to: 1163 State Street, Salem, OR 97301-2563; or by hand delivery to: Fourth Floor, 1241 State Street, Salem, OR.
Your Complaint must be submitted within 60 days after the date of the Final Decision or this Final Decision cannot be changed. TCR-MD 19 B.
This document was filed and entered on November 18, 2016.
FINAL DECISION TC-MD 150355N; 160203N 14