Covenant Presbyterian Church v. Multnomah County Assessor

CourtOregon Tax Court
DecidedMay 15, 2026
DocketTC-MD 250545R
StatusUnpublished

This text of Covenant Presbyterian Church v. Multnomah County Assessor (Covenant Presbyterian Church v. Multnomah County Assessor) is published on Counsel Stack Legal Research, covering Oregon Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Covenant Presbyterian Church v. Multnomah County Assessor, (Or. Super. Ct. 2026).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax

COVENANT PRESBYTERIAN CHURCH, ) A MEMBER CONGREGATION OF THE ) PRESBYTERY OF THE CASCADES, ) ) Plaintiff, ) TC-MD 250545R ) v. ) ) MULTNOMAH COUNTY ASSESSOR, ) ) Defendant. ) ORDER

This matter is before the court on Defendant’s Partial Motion to Dismiss (Motion) filed

March 19, 2026. Plaintiff filed its response on April 1, 2026, and oral argument was held on

April 3, 2026. The matter is ready for disposition.

A. Background

Plaintiff owns real property identified as Account R338587 (subject property), which was

exempt from property taxation under ORS 307.140 as property of a religious organization.

(Compl at 1.) Defendant mailed Plaintiff a Notification of Status Change dated July 2, 2025

(Notice), stating that 19.894 percent of the subject property would become taxable beginning

with the 2025-26 tax year because “[t]he use of the property no longer qualifies in accordance

with ORS 307.140.” (Id. at 2.) Plaintiff appealed to this court on September 25, 2025, initially

challenging only the partial disqualification. (Id. at 1.) On March 3, 2026, Plaintiff amended its

Complaint to also challenge the real market value (RMV) of the subject property. (Am Compl at

4.)

Defendant’s Motion seeks dismissal of Plaintiff’s RMV claim. Defendant does not

dispute that Plaintiff timely appealed the partial disqualification. Defendant argues instead that

ORDER TC-MD 250545R 1 ORS 305.275(3) required Plaintiff to first petition the Property Value Appeals Board (PVAB)

under ORS 309.100 before seeking Tax Court review of the RMV of the subject property.

(Def’s Mot at 2.)

B. Analysis

The issue is whether a taxpayer who timely appeals a mid-year partial disqualification

from a property tax exemption directly to this court may litigate the RMV of the disqualified

portion in the same proceeding, or whether the RMV issue must first proceed through PVAB.

1. Disqualification from exemption

Appeals from a county assessor’s disqualification from a property tax exemption must be

brought to the Tax Court within 90 days. ORS 305.280.1 There is no dispute that Plaintiff’s

Complaint was timely filed as to that issue.

2. RMV appeals

To appeal a property’s roll value, a taxpayer must first file a petition with PVAB by

December 31 of the relevant tax year. ORS 309.100; ORS 305.275(3). PVAB convenes on or

after the first Monday in February of each year and must complete its work and adjourn no later

than April 15. ORS 309.026(1). An appeal from a PVAB order must be filed in the Tax Court

within 30 days after the applicable mailing or notice date. ORS 305.280(4).

3. The timing problem

The two statutory schemes do not operate on the same timetable, and that creates a

practical problem in cases like this one. The July 2, 2025, disqualification Notice triggered a

direct appeal right; Plaintiff had to file in the Tax Court within 90 days to preserve the exemption

1 The court’s references to the Oregon Revised Statutes (ORS) are to 2023.

ORDER TC-MD 250545R 2 issue. At that time, however, the ordinary PVAB petition period for the 2025-26 roll had not yet

opened. A PVAB petition could have been filed later in the year and heard when the board

convened in February 2026 and adjourned by April 15, 2026.

Defendant’s reading of the statutes would require Plaintiff to pursue two separate

proceedings on separate timetables—one in this court to challenge the disqualification, and one

before PVAB to preserve the RMV issue—both arising from the same July 2, 2025, Notice.

That procedure is awkward and fragmented. The question, therefore, is whether the statutes

should be read to compel that result.

4. Resolution

Defendant’s Motion turns on how Plaintiff’s RMV claim is characterized. If Plaintiff

were challenging only the subject property’s annual roll value, it would ordinarily be required to

petition PVAB under ORS 309.100 before seeking Tax Court review, as ORS 305.275(3) would

bar a direct appeal. But Plaintiff did not initiate this case as an ordinary roll-value appeal.

Plaintiff timely appealed the July 2, 2025, Notice partially disqualifying the subject property

from exemption. That disqualification issue is properly before this court under ORS 305.280,

and Defendant does not contend otherwise.

Defendant’s July 2, 2025, Notice did not merely place a value on the annual roll, it also

determined that a portion of the subject property would no longer be exempt. Plaintiff was

required to challenge that disqualification directly in this court within the applicable 90-day

period.

PVAB does not have the authority to decide whether the subject property, or a portion of

it, qualified for exemption under ORS 307.140. See Sisters of Charity v. Washington County

ORDER TC-MD 250545R 3 Board of Commissioners, 3 OTR 106, 108 (1967) (stating PVAB2 is “without jurisdiction to

grant or deny claims for exemption”).

The narrower question is whether Plaintiff must separately petition the related RMV issue

to PVAB, even though that issue becomes relevant only if Defendant’s partial disqualification is

sustained. The court concludes that ORS 305.275(3) does not require that result. Two distinct

appeal paths exist under the statutes. Ordinary annual value disputes generally begin with

PVAB, while challenges to certain assessor acts, orders, omissions, or determinations may

proceed directly to this court when no other statutory right of appeal is available. This court has

previously described that distinction in River Vale Limited Partnership v. Department of

Revenue, 24 OTR 468 (2021), differentiating the regular annual property tax valuation process

from the all-purpose process for appealing an act, omission, order, or determination of a tax

official. In River Vale, the court explained that ORS

Related

River Vale Limited Partnership v. Dept. of Rev.
24 Or. Tax 468 (Oregon Tax Court, 2021)

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Covenant Presbyterian Church v. Multnomah County Assessor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/covenant-presbyterian-church-v-multnomah-county-assessor-ortc-2026.