Fidler v. Deschutes County Assessor

CourtOregon Tax Court
DecidedSeptember 8, 2025
DocketTC-MD 250045G
StatusUnpublished

This text of Fidler v. Deschutes County Assessor (Fidler v. Deschutes 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
Fidler v. Deschutes County Assessor, (Or. Super. Ct. 2025).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax

MATTHEW FIDLER ) and WE'RE THE WURST, ) ) Plaintiffs, ) TC-MD 250045G ) v. ) ) DESCHUTES COUNTY ASSESSOR, ) ) ORDER ON DEFENDANT’S Defendant. ) MOTION TO DISMISS

Defendant moves to dismiss Plaintiffs’ Complaint appealing the real market value of

personal property. The subject property is identified in Defendant’s records as Account 278367,

and the tax years at issue are 2021-22, 2022-23, and 2023-24.

I. FACTS

Plaintiff Matthew Fidler owns and operates We’re the Wurst, a butchering and meat

processing business based in Redmond. (Compl at 3.)

Plaintiffs moved to Redmond from Bend “[d]uring 2020-2021” to participate in an

Enterprise Zone tax incentive. (Id. at 7.) Fidler visited the office of the zone sponsor, Redmond

Economic Development, Inc. (REDI), and received “verbal confirmation” that his paperwork

was sufficient to qualify Plaintiffs for Enterprise Zone (EZ) exemption. (Id.) Defendant agrees

that “[t]he business was approved for 2022 EZ during 2021” after Plaintiffs filed a 2021 personal

property return. (Marshall Decl at 3.)

Defendant subsequently determined Plaintiffs were “disqualified by operation of law

from the EZ” for tax year 2022 and subsequent years. (Marshall Decl at 4.) Defendant alleges

Plaintiffs “failed to make a claim for business personal property tax exemption under ORS

///

ORDER ON DEFENDANT’S MOTION TO DISMISS TC-MD 250045G 1 of 7 285C.175 each year following 2021” because they did not file personal property tax returns or

enterprise zone property schedules. (Id. at 3.)

Defendant assessed the subject account for 2022-23 and 2023-24 “with estimated values

based on the business’s reporting in 2021[.]” (Marshall Decl at 3.) The subject’s 2024-25

personal property tax statement shows delinquent taxes owed for 2022-23 and 2023-24. (Compl

at 2.) It shows no taxes owing for 2021-22. (Id.)

Plaintiffs do not challenge their disqualification from enterprise zone exemption. Rather,

they challenge the subject account’s tax roll real market values, which they claim were

overstated for the years at issue because Defendant “charged for equipment long gone,

equipment which was sheltered under REDI program and equipment that I was personally selling

for other people.” (Compl at 7, emphasis in original.) Plaintiffs filed their Complaint directly in

this court, without first petitioning the Deschutes County Property Value Appeals Board

(formerly the Deschutes County Board of Property Tax Appeals) for any of the years at issue.

II. ANALYSIS

At issue is whether Plaintiffs have shown good and sufficient cause under ORS 305.288

for failing to timely pursue their statutory right of appeal.1 Defendant moves to dismiss the

appeal on three grounds: (1) that Plaintiffs failed to first petition the board, (2) that Plaintiffs’

Complaint was untimely as an appeal of an assessor’s action, and (3) that Plaintiffs do not

qualify for the enterprise zone exemption. Plaintiffs admit the factual bases of the first two

grounds and do not contest the subject’s exemption status; they allege that they meet the

conditions set by ORS 305.288(3) for receiving relief outside the usual appeals process.

1 The court’s references to the Oregon Revised Statutes (ORS) are to 2023. The cited statutes did not materially change over the relevant time period.

ORDER ON DEFENDANT’S MOTION TO DISMISS TC-MD 250045G 2 of 7 A. ORS 305.288

The statutory means of appealing a value error on the tax roll is by filing a petition with

the county property value appeals board by December 31 after the property tax statement is

issued. See ORS 309.100. Orders of that board may in turn be appealed to the Magistrate

Division within 30 days. ORS 309.110(7); 305.280(4). The statute allowing appeals directly to

this court specifically excludes appeals where “a taxpayer may appeal to the property value

appeals board under ORS 309.100[.]” ORS 305.275(3).

Nevertheless, taxpayers and taxing authorities may seek corrections to recent tax rolls

outside the usual statutory appeal process, provided there is “good and sufficient cause” for not

pursuing the statutory right of appeal. ORS 305.288(3). That right to relief is for the current and

two immediately preceding tax years. Id. Good and sufficient cause is defined narrowly:

“(b) ‘Good and sufficient cause’:

“(A) Means an extraordinary circumstance that is beyond the control of the taxpayer, or the taxpayer’s agent or representative, and that causes the taxpayer, agent or representative to fail to pursue the statutory right of appeal; and

“(B) Does not include inadvertence, oversight, lack of knowledge, hardship or reliance on misleading information provided by any person except an authorized tax official providing the relevant misleading information.”

ORS 305.288(5). To obtain relief under ORS 305.288(3), a plaintiff must show (a) that an

extraordinary circumstance occurred and (b) that the circumstance caused the failure to appeal.

Karamanos Holdings Inc. v. Multnomah County Assessor, 21 OTR 198, 202 (2013).

Extraordinary circumstances include “death or serious illness; unavoidable and unforeseen

absence; lapses in the assessor’s performance of his or her duties; or fire, disaster, or other

casualty.” Kirtz v. Washington County Assessor, TC-MD 021123A, 2002 WL 32107259 at *2

ORDER ON DEFENDANT’S MOTION TO DISMISS TC-MD 250045G 3 of 7 (Or Tax M Div, Dec 27, 2002), quoted in Russell Fellows Properties, LLC v. Multnomah County

Assessor, TC-MD 220307N, 2022 WL 16948232 at *2 (Or Tax M Div, Nov 15, 2022).

Here, Plaintiffs allege as an extraordinary circumstance that they “never received any

written notice of removal” from the enterprise zone program and thus failed to appeal because

they assumed their property was still tax exempt. (Ptfs’ Response at 1, emphasis in original.)

Defendant does not dispute Plaintiffs’ allegation that it gave no special notice of the

disqualification, asserting that Plaintiffs’ property was disqualified “by operation of law.”

The enterprise zone exemption is authorized by ORS 285C.175 for qualified properties of

qualifying business firms. That statute clearly establishes a notice requirement and a right of

appeal when a property is denied an enterprise zone exemption:

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Related

Karamanos Holdings Inc. I v. Dept. of Rev.
21 Or. Tax 198 (Oregon Tax Court, 2013)
United Streetcar, LLC v. Dept. of Rev.
23 Or. Tax 418 (Oregon Tax Court, 2019)

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Bluebook (online)
Fidler v. Deschutes County Assessor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fidler-v-deschutes-county-assessor-ortc-2025.