Mednansky v. Dept. of Rev.

Oregon Tax Court·Decided January 20, 2026·No. TC 5465·Unpublished

Opinion

IN THE OREGON TAX COURT REGULAR DIVISION Property Tax

DAVID JOHN MEDNANSKY, ) ) Plaintiff, ) TC 5465 v. ) ) DEPARTMENT OF REVENUE, ) State of Oregon, ) ) Defendant, ) ) ORDER DENYING PLAINTIFF’S and ) MOTION FOR RECONSIDERATION OF ) ORDER DENYING PLAINTIFF’S CURRY COUNTY ASSESSOR, ) MOTION FOR REMOTE APPEARANCE ) VIA WEBEX FOR FEBRUARY 4, 2026 Defendant-Intervenor. ) TRIAL

This matter is before the court on Plaintiff’s Motion for Reconsideration of Denial for

Remote Appearance via Webex for February 4, 2026, Trial, and the objection filed on January

14, 2026, by Defendant-Intervenor (the County). Defendant Department of Revenue did not file

a separate objection. The order at issue is the court’s January 7, 2026, order denying Plaintiff’s

request to testify by remote means at trial set for February 4, 2026.

Plaintiff’s motion for reconsideration addresses one issue first raised in Plaintiff’s

January 5, 2026, motion (financial hardship due to travel costs), and adds a new issue (his

assertion that he does not intend to testify and that he sees no need to take testimony of the

County’s witnesses). The court denies Plaintiff’s motion for reconsideration without prejudice

to his right to file a supplemental motion addressing either or both of the two issues in the

manner described below.

ORDER DENYING PLAINTIFF’S MOTION FOR RECONSIDERATION OF ORDER DENYING PLAINTIFF’S MOTION FOR REMOTE APPEARANCE VIA WEBEX FOR FEBRUARY 4, 2026 TRIAL TC 5465 Page 1 of 6 As to financial hardship, Plaintiff’s declarations and exhibits paint an incomplete picture

of Plaintiff’s financial ability to attend trial and do not therefore allow the court to find good

cause to grant Plaintiff’s motion. However, the court will grant the Plaintiff until January 23,

2026, to file a supplemental motion for reconsideration containing specific data requested below.

If Plaintiff does so, the court will review Plaintiff’s information, along with any objection raised

by the County or Defendant on or before January 27, 2026, and make a determination based on

all the facts.

As to Plaintiff’s statements that he does not intend to give or present testimony of any

witness, including himself, and that he sees no need to cross-examine witnesses, the court will

allow Plaintiff to appear by remote means if, on or before January 23, 2026, he files a

supplemental motion for reconsideration and attaches a declaration waiving his rights as set forth

below.

I. ANALYSIS

A. Financial Inability to Attend Trial

Plaintiff previously stated that he would need to incur mileage and lodging costs to make

the 250-mile drive each way to trial, but that he cannot afford to do so because his “monthly

income is from Social Security and is significantly below the poverty level.” (Mot Remote

Appearance at 1.) On reconsideration, Plaintiff adds evidence of dental expenses totaling

$5,435.95 that he incurred after the court set trial in person. 1 (See Ptf’s Mot Reconsider, Ex 2

(Sept 8, 2025, receipt for dental charges totaling $2,200); id. Ex 3 (Sept 16, 2025, receipt for

dental charges totaling $3,807.00, less adjustment of $571.05, with $3,235.95 paid in cash.).)

The County asserts that these receipts “total[] less than $3,500.” (Def-Inv’s Obj Ptf’s Mot Reconsider 1

Denial Remote Appearance at 2.) The court does not understand the basis of the County’s computation.

ORDER DENYING PLAINTIFF’S MOTION FOR RECONSIDERATION OF ORDER DENYING PLAINTIFF’S MOTION FOR REMOTE APPEARANCE VIA WEBEX FOR FEBRUARY 4, 2026 TRIAL TC 5465 Page 2 of 6 Plaintiff declares that these expenses consumed all his savings and materially reduced his ability

to afford to travel to Salem for trial, compared to May 2, 2025, when the court set trial to be held

in person.

The County objects that Plaintiff’s proffered evidence of financial hardship fails to show

good cause, arguing: “Although Plaintiff attaches three documents reflecting medical costs for

dental procedures totaling less than $3,500--which reflect that they were paid in full in cash--he

provides no evidence of income, monthly expenses, or current assets to support the claim that

these payments rendered in-person attendance financially impossible.” (Def-Inv’s Obj Ptf’s Mot

Reconsider Denial Remote Appearance at 2.)

The court agrees that Plaintiff has not attempted to substantiate his entire household

financial situation, including assets and liabilities, sources of cash that do not constitute income,

and limited documentation. The court is unpersuaded by the evidence submitted by Plaintiff to

date and will therefore decline to allow him to testify by remote means. However, this order will

allow Plaintiff to submit additional substantiating evidence using the court’s existing form for

income tax cases involving “substantial hardship” as directed below. If Plaintiff chooses to

submit additional evidence, the court’s inquiry will consider the information provided, along

with any objections from Defendant or the County.

B. Potential Waiver of Rights To Testify and Cross-Examine

Plaintiff’s Motion for Reconsideration also includes additional declarations about his

planned course of conduct at trial that go to the basis of the court’s decision under Tax Court

Rule (TCR) 59 and ORS 45.400. 2 Plaintiff states that he “did not intend to present evidence into

2 Unless otherwise noted, the court’s references to the Tax Court Rules (TCR) and the Oregon Revised Statutes (ORS) are to the 2026 editions. ORDER DENYING PLAINTIFF’S MOTION FOR RECONSIDERATION OF ORDER DENYING PLAINTIFF’S MOTION FOR REMOTE APPEARANCE VIA WEBEX FOR FEBRUARY 4, 2026 TRIAL TC 5465 Page 3 of 6 this case based on his testimony,” that “there is no need to bring witnesses to present his case,”

and that he “sees no reason to question any witness the Defendant may bring.” (Ptf’s Mot

Reconsider at 1.) Plaintiff’s position that he “sees no reason” to question any witness of the

County appears to be based on a belief that his theory of the case entitles him to win without

regard to the appraisal evidence that the County has exchanged under the court’s rules.

Plaintiff appears to offer to waive his rights to (1) present testimony (his own, or of other

witnesses) in his case in chief and on rebuttal (except perhaps for the purpose of authenticating

his exhibits), and to (2) cross-examine any witnesses of the County or Defendant. As the County

implies in its objection, a knowing waiver on those terms would alleviate the need of the County

or Defendant to observe Plaintiff in person to assess his credibility. (Def-Inv’s Objection at 3

(“the County would accept and stipulate to Plaintiff’s waiver of his right to introduce or offer

testimonial evidence”). 3 Such a waiver also would eliminate the need for Plaintiff to observe the

County’s or Defendant’s witnesses in person when they testify on the County’s behalf.

The court is willing to approve Plaintiff’s request if the court receives a knowing waiver

from Plaintiff along the lines stated above. Plaintiff previously has been informed by the court

that the same procedural rules, including the rules of evidence, apply to him that would apply to

a party represented by counsel. He has been informed by the court of his burden of proof in his

property valuation case.

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Related

§ 45.400
Oregon § 45.400