Daimler Trucks North America LLC v. Multnomah County Assessor

• Court: Oregon Tax Court
• Decided: November 10, 2025
• Docket: TC-MD 230255R
• Status: Unpublished

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax

DAIMLER TRUCKS NORTH AMERICA ) LLC, ) ) Plaintiff, ) TC-MD 230255R / 230259R ) v. ) ) MULTNOMAH COUNTY ASSESSOR, ) ) Defendant. ) DECISION

Plaintiff appealed the Multnomah County Board of Property Tax Appeal orders, mailed

April 12, 2023, for Accounts R540494, R540481, and R672244, for the 2022-23 tax year. A trial

was held on September 24 and 25, 2024, at the Oregon Tax Court. Alex Robinson, an attorney

with CKR Law Group, P.C., appeared on behalf of Plaintiff. Owen Bartels (Bartels), an

appraiser with NW Value Consulting, testified on behalf of Plaintiff. Carlos Rasch, Assistant

County Counsel for Multnomah County, appeared on behalf of Defendant. Mark Pomykacz

(Pomykacz), an appraiser with Federal Appraisal LLC, testified on behalf of Defendant.

Plaintiff’s exhibits PE1 to PE479 (including corrected pages) and Defendant’s exhibits DE1 to

DE222 were received into evidence. Post-trial briefs were received on November 14, 2024.

I. STATEMENT OF FACTS

A. Overview

The subject properties consist of three office buildings commonly referred to as Nova,

TEC, and Corp 9. Located on the south side of Swan Island in Portland, Oregon, the subject

properties are owned and operated as part of Plaintiff’s corporate headquarters campus. They are

situated within the Portland/Vancouver metropolitan statistical area (MSA). (PE10.) Nearly half

of Oregon’s population resides within this MSA. (PE11.)

DECISION TC-MD 230255R & 230259R 1 1. Nova building

The Nova building is a nine-story, owner-occupied, Class A office facility constructed by

Plaintiff in 2016. (DE31-DE33.) The building contains approximately 267,280 square feet and

is located on a 10.38-acre parcel in a predominately industrial area. (Id.; PE5.) A 242,720

square foot, four story, parking garage was constructed with the building and serves all the

subject properties, although additional surface lots exist for the other buildings. (PE5.)

The Nova building includes high-end carpet tile, tiled restrooms, drop-acoustical tile

ceilings with LED lighting, and painted gypsum walls – that Plaintiff characterizes as very good

quality finishes. (PE24). The entrance features a two-story atrium containing a showcase truck,

a small café, meeting rooms and workstations scattered throughout. (PE25-PE27.)

2. TEC building

Plaintiff acquired the TEC building, originally constructed in 1977, and substantially

remodeled it in 2016. (PE141) The building has approximately 215,104 square feet of office

space and on an 11.6 acre parcel. As of the assessment date, the building had some failing

façade, which was noted in Plaintiff’s report as diminishing value. (PE141.)

3. Corp 9 building

The Corp 9 building was originally constructed in 1986 as a research and development

facility. (PE361.) Corp 9 includes approximately 58,938 square feet and is located on a 4.98-

acre parcel. (PE357.) Plaintiff purchased the property in 1999, later expanding and repurposing

it as part of its headquarters campus. (PE357.) As of the assessment date, the building housed

Plaintiff’s daycare operations, a shipping and receiving bay, and open-format office space. (Id.)

Although the northern portion of the building was initially designed as an indoor sport court for

employees, it was ultimately converted to additional office space. (PE 365.)

DECISION TC-MD 230255R & 230259R 2 4. Land valuation and appraisal information

The parties agreed to the land values; therefore, land valuation was excluded from the

appraisal reports. Although located on separate tax lots, all three buildings are physically

contiguous, owned by Plaintiff, and function as an integrated corporate headquarters campus.

While Plaintiff submitted three standalone appraisals for the properties, it acknowledged their

operational integration. Defendant submitted a single appraisal treating the buildings as one

special purpose property.

B. Plaintiff’s Appraisal Methodologies and Conclusions

1. Nova building

Bartels testified that he is a Certified General Appraiser with over 20 years of experience,

prepared appraisal reports for each of the three buildings. (PE3.) For the Nova building, he

developed the cost, sales comparison, and income capitalization approaches. He concluded that

the highest and best use of this building was continued use as a corporate office facility. (PE35-

PE36.) The appraisal did not treat the building as special purpose, despite acknowledging its

integration into the larger campus. (Id.)

Bartels testified that market feedback suggested that the Covid-19 pandemic had a

negative impact on value; however, on cross examination he testified that available sales data did

not confirm this as of the assessment date. (PE13.) He identified the potential buyer pool as

regional and national owner-users.

a. Cost approach - Nova

Plaintiff’s actual construction cost for Nova was approximately $128.9 million. (PE43.)

Adjusted using Federal Reserve Bank economic data, the estimated cost to build as of the

assessment date was $152.8 million. (PE45.) Using the Marshall & Swift valuation data, Bartels

DECISION TC-MD 230255R & 230259R 3 estimated the replacement cost at $116.4 million, deducted $20.6 million for depreciation, added

the assessor’s land value of $10.9 million, and concluded a cost-based value of $99,348,794.1

This approach was given the least weight due to limitations in market-derived depreciation

estimates for such a specialized structure. (PE41-PE48).

The actual cost for the parking garage was $20,642,648, while Marshall & Swift data

estimated the cost at $16,699,136. (PE43, PE46.) Bartels estimated the surface lot cost at $7.50

per square foot and structured parking cost at $69 per square foot. (Id.)

b. Sales comparison approach - Nova

Bartels analyzed ten sales of comparable properties, adjusting for location, age, quality,

and parking. (PE49-PE68) Five of the comparable sales were located in the Seattle MSA, three

in the Portland MSA, and one in Phoenix, Arizona. He acknowledged the differences between

these markets but maintained that the comparables were appropriate, despite adjustments

averaging around 50 percent. Adjusted prices ranged from $89 to $448 per square foot. (PE67.)

Bartels concluded a reconciled value of $85,530,000, or approximately $320 per square foot.

(PE69.)

Of the ten comparable sales, Comparable 5 included a confirmed parking structure; the

nine properties had surface lots or lacked parking data. (PE53–PE62.) The subject property’s

parking garage, at 242,720 square feet, accommodates 1,380 cars and 12 motorcycles—equating

to 6.57 spaces per 1,000 square feet of building area. (PE23, PE29.) Bartels did not assign a

separate value to the parking garage, which had an actual construction cost of $20.6 million.

(PE43.)

1 Bartels conceded on cross-examination that he incorrectly calculated the height of the building, and his numbers should have increased by .5% for every floor above three.

DECISION TC-MD 230255R & 230259R 4 c. Income approach - Nova

Market rent was estimated at $24 per square foot, with a 15 percent vacancy rate and a

6.5 percent capitalization rate. (PE88.) After applying expenses and reserves, the income

approach yielded a value of $87,260,000. (Id.)

d. Reconciliation - Nova

Bartels gave primary weight to the sales comparison approach and secondary weight to

the income approach. (PE89) He considered the cost approach to have limited utility due to

rapid increases in construction costs. He concluded a total value for the Nova building at $86

million. (Id.) He allocated this value as follows: $73,903,320 for R672244; $11,469,100 for

R699546; and $627,580 for R699099. (PE90.)

Bartels developed only the sales comparison and income capitalization approaches for the

TEC building, and he excluded the cost approach due to the building’s age. (PE183.) He

concluded that the highest and best use of the building was continued use as a corporate office

facility. (PE176-PE180)

Bartels used the same set of comparable properties as for the Nova building. (PE67;

PE203.) Adjusted sales prices ranged from $73.72 to $368.23 per square foot. (PE203.) He

initially valued the property at $225 per square foot, or $48,398,400, but applied a downward

adjustment of $9.63 million for deferred façade maintenance. (PE205) Bartels included a report

on the façade, with repair estimates ranging from $5.3 million to nearly $13 million. (PE286-

PE289.) He considered the cost of repair to have increased due to inflation—estimated at 46

percent—and applied the $9.63 million adjustment as a lump-sum depreciation factor. (PE170.)

Although Plaintiff undertook substantial renovations to the building in 2016, it did not repair the

DECISION TC-MD 230255R & 230259R 5 façade. (PE141.) After analysis, Bartels concluded a value using the sales comparison approach

of $38,770,000, or $180 per square foot. (PE227.)

For the income approach, Bartels selected five comparable leases. (PE208.) Four were

located in the Portland MSA and one in Seattle. (Id.) He noted that the subject property was

larger than all of the comparables and that lease rates varied significantly. (PE216.)

Bartels estimated market rent at $20 per square foot, yielding gross potential income of

$4,302,080. (PE219.) After applying a 15 percent vacancy rate, 3 percent for management, 1.18

percent for reserves, and a cap rate of 6.75 percent, plus the deferred maintenance deduction, he

concluded a value of $42,280,000. (PE226.)

Bartels reconciliation gave greater weight to the sales comparison approach. He

concluded a final market value of $40 million. (PE227.) He allocated the value as follows:

$27,367,000 for R540494; and $12,633,000 for R699098. (Id.)

Bartels applied only the sales comparison and income approaches for the Corp 9 building.

(PE357.) He concluded that the highest and best use of the property was continued office use,

consistent with its current occupancy. (PE361.) He did not consider the daycare or shipping

functions to indicate special purpose use. (PE409.) Based on comparable office buildings of

similar age and use, Bartels concluded a value of $8.25 million, or $140 per square foot. (Id.)

For the income capitalization approach, Bartels selected four comparable properties

located in the Portland MSA. (PE412; PE 421.) He estimated market rent at $16 per square

foot, yielding gross income of $943,008. (PE427.) After applying a 7 percent vacancy factor, a

7.25 capitalization rate, and deductions for expenses, he concluded a value of $8.160 million.

(Id.)

DECISION TC-MD 230255R & 230259R 6 Bartels gave primary weight to the sales comparison approach because he believed that

approach is “most indicative of pricing applied by owner-users.” (PE428.) Bartels gave the

income capitalization approach secondary weight “only because of the subject’s owner-user

nature and the limitation of data [regarding office leases of the subject property’s size and of

capitalization rate indications].” (Id.) His reconciliation value was $8.225 million allocated as

follows: $5,927,160 for R699547; and $2,297840 for R540481. (PE361 Corrected.)

C. Defendant’s Appraisal Methodologies and Conclusions

Pomykacz is the managing partner of Federal Appraisal LLC and holds the MAI

designation from the Appraisal Institute. (DE107.) He has over 35 years of experience in

complex commercial property valuation and litigation support, including corporate headquarters

and special purpose campuses. (Id.)

Pomykacz developed the sales comparison and cost approaches. He did not apply an

income approach due to insufficient market data for special purpose headquarters campuses.

(DE57-DE58.)

1. Sales comparison approach

Pomykacz selected six property sales, all within the Portland central business district

(CBD). (DE65.) Based on a comparison chart where he made adjustments, Pomykacz

determined the value of the land and improvements was $340 per square foot or $275,000,000.

(DE67.) He subtracted the land only value of $30,656,840, which left $244,343,160 for

improvement only value. (Id.) He made 15 percent location adjustments for all properties due to

their CBD location. (DE68.) He made size adjustments ranging from 18 to 34 percent. Total

adjustments ranged from 25 to 55 percent. (Id.)

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DECISION TC-MD 230255R & 230259R 7 Pomykacz valued the entire site – approximately 27 acres with over 530,000 square feet

of office and special functional space – as a single, integrated corporate headquarters. (DE3-

DE5; DE25.) He did this citing the interdependence of buildings, shared parking, LEED

certification (Nova), and cohesive functionality. (Id.) He testified the market for such campus

was extremely limited, constituting a “market of one” and asserted that breaking it into

standalone buildings would misrepresent market conditions. For this reason, Pomykacz

explained his valuation relied significantly on the cost approach. On cross examination, he

indicated that his valuation reflected the value to the current user, and that a potential buyer

would likely not pay an amount equivalent to the cost of construction. He stated: “if any

corporate campus or headquarters sells, I would expect it to sell for less than the cost to build it.”

2. Cost approach

Pomykacz primarily relied on the cost approach using Marshall & Swift Valuation

Service, which allows estimates of the replacement cost new for all three buildings and the

parking garage. For Nova, he estimated the cost per square foot at $360.50. He then added

sprinkler costs and applied a cost multiplier based on the building’s height. Finally, he included

a 12 percent entrepreneurial profit, arriving at a replacement cost new of $119,034.545. (DE79.)

Although he determined the building’s age was 6 years of a 60 year life, he deducted

depreciation of 2 percent, leaving a value of $116,653,854. He added $23,569,303 for the four-

story parking lot, $2,730,124 for landscaping, and $188,130 for a surface parking lot, for a

rounded total of $143 million. (Id.)

For the TEC building, Pomykacz estimated a cost per square foot of $259, added for

sprinklers and cost multipliers, and 12 percent for entrepreneurial profits, for a total cost of

$63,422,185. (DE80.) Although the actual age of the facility was 25 years, he determined the

DECISION TC-MD 230255R & 230259R 8 effective age was 17.67 years. (Id.) He deducted 8 percent for depreciation, added landscaping,

and a surface parking lot, to arrive at a rounded total of $61 million. (Id.)

For the Corp 9 building, Pomykacz used a base square foot rate of $203, added

sprinklers, added a local multiplier and entrepreneurial profit of 12 percent to find replacement

cost new at $12,977,166. (DE81.) He determined its actual age at 36 years, its effective age at

25.33 of a 55 year economic life, and deducted 19 percent physical depreciation. (Id.)

Pomykacz did not apply a deduction for obsolesce in valuing the property, which is currently

used as a daycare. He added landscaping, surface parking, playground area for a rounded total of

$12 million. (Id.)

In his final reconciliation, Pomykacz placed all of the weight on the cost approach, citing

the difficulty in estimating a precise market rent for special purpose headquarters and the

absence of sufficient market transactions to make valuation determinations with high confidence.

(DE83.) His conclusions were described as follows:

“The Subject property is a corporate campus. It is owner occupied, designed and built for the owner’s specific real estate needs. These buildings function as one economic unit. They include special designs and finishes that support the corporate function. They can be described as special improvements and as having special purposes and needs that go beyond general office buildings that are intended to be rented. The Subject improvements cannot be directly compared to rental office buildings. Appraisal theory indicates that special, rare property types are often better appraised via the cost approach.”

(DE83.)

II. ANALYSIS

The central issue in this case is the real market value of the subject properties for the

2022-23 tax year. Specifically, the court must determine whether the properties should be valued

individually as conventional office buildings, as Plaintiff contends, or collectively as a special

purpose corporate headquarters campus, as Defendant contends. This determination turns on the

DECISION TC-MD 230255R & 230259R 9 properties’ highest and best use, the behavior of market participants, and whether the properties

meet Oregon’s definition of special purpose property. Secondarily, the court must determinate

whether the parties met their respective burdens of proof.

Under ORS 308.205(1),2 real market value is defined as:

“the amount in cash that could reasonably be expected to be paid by an informed buyer to an informed seller, each acting without compulsion in an arm’s-length transaction occurring as of the assessment date for the tax year.”

The assessment date for the 2022-23 tax year was January 1, 2022. See ORS 308.007; 308.210.

A property’s highest and best use requires considering property that is legally permissible,

physically possible, financially feasible, and maximally productive.

Importantly, Oregon adheres to a value-in-exchange standard, as clarified in STC

Submarine, Inc. v. Dept. of Revenue, 320 Or. 589 (1995). This approach values property based

on what the market would pay, rather than its value to the current owner —a concept known

as value in use. See The Appraisal of Real Estate, 15th ed., at 52-54.

As the party seeking to reduce the tax roll value, Plaintiff, bears the initial burden of

proof. Defendant, seeking to increase the roll value, bears the burden of proof on that issue.

ORS 305.427. The applicable standard is a preponderance of the evidence. Id. Importantly, the

court must determine the value in exchange, not the value in use, and must evaluate the

properties from the perspective of a hypothetical market participant, not the current user. See

Truitt Brothers, Inc. v. Dept. of Rev., 10 OTR 111, 114 (1985).

Oregon law recognizes that certain properties, commonly referred to as “special purpose

properties,” may require alternative valuation methods when there are few buyers or comparable

sales. See Les Schwab Tire Centers of Oregon v Crook County Assessor, 14 OTR 588 (1999);

2 References to the Oregon Revised Statutes (ORS) are to the 2021 edition.

DECISION TC-MD 230255R & 230259R 10 ORS 308.205(2)(c); OAR 150-308-0240(3).3 Under ORS 308.205(2)(c), if a property has “no

immediate market value,” its real market value is the amount that would justly compensate the

owner for its loss. To justify special purpose treatment, the proponent must demonstrate that the

property’s physical, functional, or legal characteristics of the buildings make them not readily

adaptable to general market uses, thereby limiting the potential buyer pool. Les Schwab, 14 OTR

at 593 (requiring evidence that property’s marketability is materially constrained).

A. Factors Favoring a Special Purpose Asset Designation

The parking garage serves multiple buildings and is physically and functionally

integrated into the site. This integration complicates the independent marketing of the buildings,

as a hypothetical buyer of one building may depend on shared parking rights that are not easily

severed. Additionally, the use of part of the Corp 9 building as a daycare is atypical for general

office space. While this use could be repurposed, it may deter conventional office tenants or

buyers. Corp 9’s relatively small size, at approximately 59,000 square feet, and specialized

design reduce its comparability to standard multi-tenant office buildings.

B. Factors Favoring Separate Valuation

Despite the features noted above, the evidence does not support treating the properties as

a single special purpose asset. Plaintiff constructed the Nova building but acquired the TEC and

Corp 9 buildings later. They were not originally developed as a unified corporate campus; the

buildings had some prior functional independence. Defendant did not identify structural

characteristics that render the buildings unsuitable for general office use. Rather, Pomykacz,

emphasized their current use, which improperly shifts the analysis toward value in use rather

than value in exchange.

3 Oregon Administrative Rules (OAR)

DECISION TC-MD 230255R & 230259R 11 Although the daycare use is unusual, it comprises a minor portion of the overall property

portfolio. No evidence was presented to show that conversion to general office use would be a

prohibitive expense. These factors suggest that the buildings retain market adaptability and

independent utility, undermining Defendant’s argument for treating them as an inseparable

special use property.

In Les Schwab Tire Centers v Crook County Assessor, 14 OTR 588, 594 (1999), this

court considered whether a large warehouse complex used for tire distribution had an

“immediate market.” Id. at *3. The court concluded that it did not, noting the absence of

comparable sales or rentals. While the court accepted the property as a single unit for valuation,

it did so based on the parties’ agreement, not because segmentation was impractical or due to

functional integration. Id. at 590–94.

Oregon Department of Revenue rules further clarify that where no comparable market

transactions exist, it is appropriate to rely on the cost or income approaches. See OAR 150-308-

0240(2)(d). Special purpose property is defined as property specially designed and used for a

specific operation, often lacking market comparable. OAR 150-308-0240(3). However, the

absence of comparables alone does not justify special purpose treatment; the property must also

lack adaptability to general market uses.

Pomykacz emphasized that the physical proximity, operational integration, and exclusive

use of the buildings by Plaintiff made it appropriate to value the subject property as a special

purpose headquarters facility. He cited shared amenities such as the common parking garage and

daycare in Corp 9 as evidence of a single economic unit. However, these features, even in

combination, do not establish the degree of integration required for special purpose designation.

Most critically, Pomykacz’s appraisal relies heavily on the property’s current use, which aligns

DECISION TC-MD 230255R & 230259R 12 more closely with a value-in-use standard, contrary to ORS 308.205(1). While Defendant raises

valid concerns about the campus-like nature of the subject properties, Plaintiff’s approach better

aligns with the statutory definition of real market value. Thus, the court determines the subject

properties should be evaluated separately and not as a unit.

C. Whether Plaintiff Has Met Its Burden of Proof

Plaintiff submitted separate appraisal reports for the Nova, TEC, and Corp 9 buildings,

treating each as a conventional office property. Each report applied standard valuation methods,

including the sales comparison and income capitalization approaches. The Nova appraisal also

included a cost approach. All three reports concluded that the highest and best use of the

properties was continued office use and did not identify any physical or regulatory barriers to

independent sale or marketing.

While Bartels acknowledged errors in some summary tables, his overall analysis was

generally persuasive. For the Nova building, he concluded a sales comparison value of $320 per

square foot. Pomykacz’s valuation of the entire campus at $340 per square foot is not materially

different. However, the treatment of the parking garage represents a significant divergence.

Bartels assigned no value to the parking garage, despite its documented construction cost of over

$20 million. Only one of the ten sales comparables included a parking garage, and that facility

offered significantly fewer spaces. The subject property provides 6.57 spaces per 1,000 square

feet of building area—well above market norms. Despite this, Bartels made no adjustment for

the parking garage. The court finds this omission unjustified. While it cannot simply add $20

million to the sales comparison value, the absence of any valuation or adjustment for such a

substantial asset undermines the reliability of the Nova appraisal. Given the lack of a viable

alternative valuation and the acknowledged limitations of the cost approach, the court concludes

DECISION TC-MD 230255R & 230259R 13 that Plaintiff has not met its burden of proof with respect to the Nova building.

For the TEC building, Bartels concluded a value of $225 per square foot, or $48,398,400.

(PE204.) He applied a $9.63 million deduction for deferred façade maintenance. However, this

adjustment was not adequately supported. While Plaintiff provided cost estimates, it did not

submit contractor bids or explain why the repairs were neglected during prior renovations. The

court finds the valuation of the building persuasive overall but gives no weight to the additional

depreciation adjustment. Accordingly, the value of the TEC building is determined to be $48.4

million.

For the Corp 9 building, Bartels applied both the sales comparison and income

capitalization approaches. He concluded that the highest and best use of the property was

continued office use, consistent with its current occupancy. He did not treat the daycare or

shipping functions as indicative of special purpose use. (PE409.)

Bartels’ sales comparison approach yielded a value of $140 per square foot, or $8.25

million. The comparables selected were generally similar in age and use, though none included

the same mix of functions as Corp 9. The building’s relatively small size—approximately

59,000 square feet—and its prior use as a research and development facility, later converted to

include daycare and shipping operations, make it somewhat atypical. However, the evidence did

not establish that these features materially constrained its marketability or adaptability for

general office use.

The income approach supported a similar valuation. Bartels estimated market rent at $16

per square foot, applied a 20 percent vacancy factor, and used an 8.75 percent capitalization rate.

After accounting for expenses, he concluded a value of $8.16 million. (PE427.)

In reconciliation, Bartels gave primary weight to the sales comparison approach and

DECISION TC-MD 230255R & 230259R 14 concluded a final value of $8.225 million, allocated between two tax accounts. (PE428.) The

court finds this valuation reasonable and supported by the record. While the building’s mixed-

use character may limit its appeal to some buyers, there was no evidence that it could not

be marketed or repurposed without undue cost. Accordingly, the court accepts Bartels’ valuation

of $8.225 million for the Corp 9 building.

III. CONCLUSION

The subject properties exhibit certain characteristics of an integrated corporate campus,

including a shared structured parking garage and a limited-use daycare located within the Corp 9

building. These features suggest that separating the properties for valuation purposes may

present logistical challenges. However, the evidence presented does not establish that the

properties possess the physical, functional, or legal characteristics necessary to warrant

classification as special purpose property. Further, Defendant did not demonstrate that the

buildings lack market adaptability or that they are incapable of being independently marketed or

sold.

With respect to the Nova building, Plaintiff’s appraisal contains material deficiencies.

Most notably, the appraisal fails to assign any value to the parking garage, despite its

documented construction cost exceeding $20 million and its significant contribution to the

functionality of the site. Given the absence of a credible valuation for this substantial asset and

the acknowledged limitations of the cost approach, the court concludes that Plaintiff has not met

its burden of proof as to the real market value of the Nova building.

As for the TEC and Corp 9 buildings, Plaintiff’s appraisals contain some errors and

insufficient support for certain adjustments, such as the deferred maintenance deduction for TEC.

Nevertheless, Plaintiff’s appraisals of these buildings are grounded in conventional valuation

DECISION TC-MD 230255R & 230259R 15 methodologies and reflect the likely behavior of informed buyers and sellers in the relevant

market. Accordingly, the court finds that Plaintiff’s appraisals more accurately reflect the real

market value of the TEC and Corp 9 buildings as of the assessment date with the exception of

deferred maintenance of the façade, as referenced above. Now, therefore,

IT IS THE DECISION OF THIS COURT that Plaintiff’s appeal is granted in part and

denied in part. Neither party presented a persuasive value for the Nova building, thus the roll

value is sustained. The value of the TEC building is $48.4 million, and the value of the Corp 9

building is $8.25 million.

RICHARD D. DAVIS MAGISTRATE

If you want to appeal this 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 this Decision or this Decision cannot be changed. TCR-MD 19 B.

This document was signed by Magistrate Richard D. Davis and entered on November 10, 2025.

DECISION TC-MD 230255R & 230259R 16