Hoggard v. Clackamas County Assessor

CourtOregon Tax Court
DecidedJuly 12, 2018
DocketTC-MD 170389G
StatusUnpublished

This text of Hoggard v. Clackamas County Assessor (Hoggard v. Clackamas 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
Hoggard v. Clackamas County Assessor, (Or. Super. Ct. 2018).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax

JOHN T. HOGGARD ) and MARY T. BURRY, ) ) Plaintiffs, ) TC-MD 170389G ) v. ) ) CLACKAMAS COUNTY ASSESSOR, ) ) Defendant. ) FINAL DECISION OF DISMISSAL1

This matter came before the court on Defendant’s Motion to Dismiss (motion) based on

the statute of limitations. Plaintiffs conceded that their Complaint, filed December 19, 2017, was

untimely. In response to the court’s order of April 24, 2018, Plaintiffs filed a letter alleging

circumstances related to their untimely filing. Defendant filed a reply.

I. FACTS

The court accepts the facts alleged by Plaintiffs as true and the attachments to the

pleadings as authentic for the purpose of deciding this motion.

Plaintiffs received a notice from Defendant entitled “Omitted Property Notice.” That

notice related appeal rights as follows:

“Should you decide to appeal this decision of the assessor, you must file a complaint with the Oregon Tax Court in the Magistrate Division. The appeal must be filed with that court as provided in ORS 305.280 and ORS 305.560 by October 17, 2017, which is within 90 days after our ‘show cause’ date of July 19, 2017.”

(Emphasis added.) Included with Defendant’s Omitted Property Notice was another document

///

1 This Final Decision of Dismissal incorporates without change the court’s Decision of Dismissal, entered June 22, 2018. The court did not receive a statement of costs and disbursements within 14 days after its Decision of Dismissal was entered. See Tax Court Rule–Magistrate Division (TCR–MD) 16 C(1).

FINAL DECISION OF DISMISSAL TC-MD 170389G 1 entitled “Omitted Property Waiver.” That waiver was provided in blank for the “owner’s

signature” and contained the following operative language:

“I agree to the following additional value of the above described property and understand that this value will be added to the Clackamas County Assessment Roll on July 19, 2017, for the year or years indicated. I also understand that by signing this waiver I do not give up my appeal rights to the Magistrate Division of the Oregon Tax Court.”

(Emphasis added.) Plaintiffs described their interpretation of the documents it received from

Defendant thus: “Correspondence from the appraiser’s office does state an appeal could be taken

to the court by October 17, 2017. Our acceptance of this, we understood, would not preclude a

later appeal.”

Plaintiffs also described several serious medical issues they confronted “[b]efore and

during” the appeal period. First, they were “advocates” who provided “help and focus” while

their sister-in-law was dying and two other close family members were undergoing procedures.

Second, Plaintiff Mary Burry “was * * * battling a number of health problems,” including a

cancer diagnosis and “severe and progressive shortness of breath, chest pain, near fainting and a

serious cardiac arrhythmia that has been all consuming over the last year.” Due to stress from

dealing with those issues, Plaintiffs were “emotionally exhausted.” Plaintiffs were also

“confused as to the timing required to respond to the * * * increased property tax assessment.”

II. ANALYSIS

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

305.288(3) for failing to timely appeal.2 Plaintiffs assert illness and a misunderstanding arising

from Defendant’s correspondence as grounds for meeting that standard.

ORS 305.288(3) states:

2 The court’s references to the Oregon Revised Statutes (ORS) are to 2015.

FINAL DECISION OF DISMISSAL TC-MD 170389G 2 “The tax court may order a change or correction applicable to a separate assessment of property to the assessment or tax roll for the current tax year and for either of the two tax years immediately preceding the current tax year if, for the year to which the change or correction is applicable, the assessor or taxpayer has no statutory right of appeal remaining and the tax court determines that good and sufficient cause exists for the failure by the assessor or taxpayer to pursue the statutory right of appeal.”

Thus, to qualify for relief under ORS 305.288(3), a plaintiff must appeal the proper tax

years, lack another statutory right of appeal, and show a circumstance meeting the

statutory definition of good and sufficient cause. That definition is provided by ORS

305.288(5)(b), which states:

“ ‘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.”

Here, because Plaintiffs concede they did not timely appeal and seek relief for the two

preceding tax years, the only issue is whether they had good and sufficient cause for

missing their appeal deadline.

A. Personal and Family Illness

To have good and sufficient cause for failing to appeal, “a taxpayer needs to show

not only that some ‘circumstance’ occurred, but also that its occurrence ‘caused’ a

failure.” Karamanos Holdings Inc. I v. Dept. of Rev., 21 OTR 198, 202 (2013).

Providing care for a spouse near death may constitute good and sufficient cause.

In Schlaadt Family Trust v. Lane County Assessor, TC-MD 070876D, WL 2583013 (Or

Tax M Div June 20, 2008), the taxpayer’s husband had been diagnosed with a brain

tumor a year before the assessment was received. By the time of the assessment, he was

FINAL DECISION OF DISMISSAL TC-MD 170389G 3 “bedridden and unable to handle family financial matters” and was increasingly

dependent on his wife and children for care. Id. In evaluating whether to accept the

parties’ stipulated agreement, the court found that both the taxpayer and her husband had

good and sufficient cause for missing that deadline—he because of his illness, and she

because caring for him left her living “in a fog,” particularly “during the last few months

of his life.” Id.

However, the coincidental death of a family member is not good and sufficient

cause where a taxpayer’s failure to appeal is due to lack of knowledge. In Harrison v.

Deschutes County Assessor, TC-MD 050091C, WL 1432470 (Or Tax M Div May 13,

2005), the taxpayer had been appointed executor for his uncle, who had died the year

before the assessment, and legal guardian of his aunt, who suffered from Alzheimer’s

disease. During the appeal period, the taxpayer traveled to New York in connection with

his uncle’s estate and his aunt’s medical needs. The taxpayer misplaced the tax statement

while lodging visitors in his home office over Thanksgiving. The court found that

although the death of taxpayer’s uncle was an extraordinary circumstance beyond his

control, the cause of the untimely filing was that taxpayer “was unaware of the deadline.”

Harrison, 2005 WL 1432470 at *2.

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Related

Karamanos Holdings Inc. I v. Dept. of Rev.
21 Or. Tax 198 (Oregon Tax Court, 2013)

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