Murray Family Trust v. Wasco County Assessor

CourtOregon Tax Court
DecidedJanuary 25, 2021
DocketTC-MD 200132N
StatusUnpublished

This text of Murray Family Trust v. Wasco County Assessor (Murray Family Trust v. Wasco 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
Murray Family Trust v. Wasco County Assessor, (Or. Super. Ct. 2021).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax

MURRAY FAMILY TRUST and ) GEORGIANA A. M. MURRAY, Trustee, ) ) Plaintiffs, ) TC-MD 200132N v. ) ) WASCO COUNTY ASSESSOR, ) ) ORDER GRANTING DEFENDANT’S Defendant. ) MOTION TO DISMISS

This matter came before the court on Defendant’s motion to dismiss (motion), requesting

that Plaintiffs’ Complaint be dismissed without identifying the basis for the motion. (Ans at 1.)

During the case management conference held May 28, 2020, the court noted that it had

previously adjudicated the 2018-19 real market value of Account 14878 (subject property) and it

would not hear an appeal on issues decided in that case. The parties agreed to a written briefing

schedule, including a deadline by which Plaintiffs were required to identify new issues presented

in this appeal. Plaintiffs filed a written response on August 20, 2020, and additional exhibits on

October 22, 2020. Defendant filed its reply on October 26, 2020, asking the court to dismiss

Plaintiffs’ Complaint because they have not identified any new issues beyond what was decided

by this court for the 2018-19 tax year. This matter is now ready for the court’s determination.

A. Plaintiffs’ Complaint and Requested Relief

Plaintiffs appeal the subject property’s value for the 2017-18 through 2019-20 tax years.

(Compl at 1.) They requested a real market value of $0 because the subject property is

“overvalued and the land is an illegal lot of record and cannot be used for anything.” (Id.) The

subject property’s 2019-20 real market value was $98,730 and its assessed value was $94,642.

///

ORDER GRANTING DEFENDANT’S MOTION TO DISMISS TC-MD 200132N 1 (Id. at 3.) The court did not receive property tax statements for the 2017-18 and 2018-19 tax

years.

Plaintiffs describe the subject property as a 20.50-acre parcel zoned “Agricultural 160

Acre minimum in the General Management Area of National Scenic Act.” (Ptfs’ Resp at 2.)

Plaintiffs report that they have identified “three comparables” that are “the Assessor’s tax

statements on these properties for the 2019-2020 [tax year].” (Id.) Plaintiffs conclude based on

those “comparables” that a value of $320 per acre is indicated.

Plaintiffs submitted exhibits that they would offer if the case proceeds to trial. (Ptfs’ Ltr,

Oct 22, 2020). They described the exhibits as “show[ing] that the [subject] property is an illegal

lot of record, if it cannot be used because of that, it has [no] value.” (Id.) The exhibits are

excerpts from the “National Scenic Area Land Use and Development Ordinance” dated from

1994; correspondence dated from 2015 concerning a “farm use inquiry” on the subject property;

a map; and documents pertaining to sales in 1973, 1990, 1995, 1996, 2002, and 2003.

B. Analysis

The issue presented concerns res judicata, or preclusion by former adjudication, which

comprises two doctrines: claim preclusion and issue preclusion. Drews v. EBI Companies, 310

Or 134, 139, 795 P2d 531 (1990).

1. Claim preclusion – 2017-18 and 2018-19 tax years

Claim preclusion provides finality to a dispute and prevents splitting a single dispute into

multiple controversies. Drews, 310 Or at 141. It “does not require actual litigation of an issue of

fact or law” though “[t]he opportunity to litigate is required.” Id. at 140. In the context of tax,

this court has barred parties from appealing the same tax year twice, even if new issues are

presented. See U.S. Bancorp v. Dept. of Rev., 15 OTR 13, 16 (1999) (“Once a tax year has been

ORDER GRANTING DEFENDANT’S MOTION TO DISMISS TC-MD 200132N 2 appealed and placed in litigation before the court, the judicial doctrine of claim preclusion

applies”); see also Carson v. Dept. of Rev., TC-MD 170296R, 2018 WL 4944956 (Or Tax M

Div, Oct 9, 2018) (taxpayers were precluded from filing an appeal raising new issues for a tax

year that was previously adjudicated by the court).

Plaintiffs’ representative Richard J. Murray (Murray) previously appealed the subject

property’s value for the 2017-18 and 2018-19 tax years. In Murray v. Wasco County Assessor,

TC-MD 180115R (Aug 14, 2018), Murray appealed the 2017-18 value of subject property. The

court dismissed the appeal because Plaintiff was not aggrieved; he sought a reduction of real

market value to $10,250, whereas the assessed value was $250.

Murray next appealed the 2018-19 value of the subject property and the case proceeded

to trial. See Murray v. Wasco County Assessor, TC-MD 190106R (Jan 16, 2020). The court

heard testimony from Murray, as well as Plaintiff Georgianna A. M. Murray, Defendant, and the

county planning director. Id. at 1. The testimony focused on whether and to what extent the

subject property could be developed. Id. at 1-3. Both Defendant and the county planner director

testified that it was not possible to determine what amount of development would be allowed on

the subject property until the owner made a request and Defendant reviewed the request. Id. at 3.

The court agreed that the subject property was impacted by restrictions based on the possible

presence of cultural resources but could not determine the extent of the impact and disagreed

with Murray that the restrictions amounted to a total ban on use of the subject property. Id. at 5.

The court denied the appeal based on insufficient evidence of real market value. Id. at 6.

Because the subject property’s 2017-18 and 2018-19 values were previously adjudicated

by this court, Plaintiffs are precluded from appealing those years again and they are dismissed.

ORDER GRANTING DEFENDANT’S MOTION TO DISMISS TC-MD 200132N 3 2. Issue preclusion – 2019-20 tax year

Plaintiffs have not previously appealed the 2019-20 tax year to this court, though they

have litigated whether the subject property is rendered worthless based on restrictions on use.

“The general rule as to property tax valuations is that each year stands by itself.”

Mittleman v. Comm’n, 2 OTR 105, 106 (1965). “[A] judicial determination of the value of real

property for one year is not conclusive as to the value of the property for a subsequent year.” Id.

at 106-107. Notwithstanding that general rule, taxpayers may be barred by issue preclusion from

litigating an issue of law or fact that was previously litigated. Drew, 310 Or at 139-140. The

Oregon Supreme Court has articulated a five-part test for issue preclusion to apply:

“1) The issue in the two proceedings is identical; 2) The issue was actually litigated and was essential to a final decision on the merits in the prior proceeding; 3) The party sought to be precluded has had a full and fair opportunity to be heard on that issue; 4) The party sought to be precluded was a party or was in privity with a party to the prior proceeding; and 5) The prior proceeding was the type of proceeding to which this court will give preclusive effect.”

Nelson v. Emerald People’s Utility Dist., 318 Or 99, 104, 862 P2d 1293 (1993) (citations

omitted).

With respect to the first two requirements, Plaintiffs assert that the subject property had

no value for the 2019-20 tax year because it was an illegal lot of record. In his 2018-19 tax year

appeal, Murray sought to establish that the subject property had no value based on restrictions on

use. That was the central issue presented to the court and decided following trial. Plaintiffs’

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Bloomfield v. Weakland
123 P.3d 275 (Oregon Supreme Court, 2005)
Nelson v. Emerald People's Utility District
862 P.2d 1293 (Oregon Supreme Court, 1993)
State Farm Fire & Casualty Co. v. Reuter
700 P.2d 236 (Oregon Supreme Court, 1985)
Hunt v. City of Eugene
278 P.3d 70 (Court of Appeals of Oregon, 2012)
Drews v. EBI Companies
795 P.2d 531 (Oregon Supreme Court, 1990)
Mittleman v. State Tax Commission
2 Or. Tax 105 (Oregon Tax Court, 1965)
U.S. Bancorp & Subsidiaries v. Department of Revenue
15 Or. Tax 13 (Oregon Tax Court, 1999)

Cite This Page — Counsel Stack

Bluebook (online)
Murray Family Trust v. Wasco County Assessor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/murray-family-trust-v-wasco-county-assessor-ortc-2021.