Walker v. Deschutes County Assessor

CourtOregon Tax Court
DecidedApril 7, 2017
DocketTC-MD 170017G
StatusUnpublished

This text of Walker v. Deschutes County Assessor (Walker 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
Walker v. Deschutes County Assessor, (Or. Super. Ct. 2017).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax

LEE WALKER and ELIZABETH WALKER, ) ) Plaintiffs, ) TC-MD 170017G ) v. ) ) DESCHUTES COUNTY ASSESSOR, ) ) Defendant. ) FINAL DECISION OF DISMISSAL1

This matter came before the court on Defendant’s motion to dismiss, made in its Answer,

filed January 20, 2017. A case management conference was held on February 7, 2017. Plaintiffs

filed a response to Defendant’s motion to dismiss on February 15, 2017. Defendant filed a reply

to Plaintiffs’ response on February 27, 2017.

I. STATEMENT OF FACTS

Plaintiffs filed their Complaint on January 6, 2016, appealing the 2016–17 tax roll real

market value of property identified as Account 208907 (subject property) to this court. They did

not appeal to the board of property tax appeals (BOPTA). Plaintiffs attached a seven-page

printout to their Complaint captioned “Deschutes County Property Information.” That printout

was dated December 11, 2016, and it included a section with the heading “Account Summary.”

(Compl at 2.) Another section of the printout, with the heading “Tax Payment History,”

recorded that the subject property’s 2016–17 tax assessment was paid in full on November 8,

2016. (Id. at 3.)

///

1 This Final Decision of Dismissal incorporates without change the court’s Decision of Dismissal, entered March 21, 2017. 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 170017G 1 The subject property was a lot in a residential subdivision in Bend that was not developed

with any structures. Its 2016–17 tax roll real market value is $175,000. Plaintiffs requested that

the court find it had a real market value of $10,000.

II. ANALYSIS

The issue is whether the court has jurisdiction the decide Plaintiffs’ appeal.

Generally, no appeal to this court is allowed where a taxpayer may appeal to BOPTA.

ORS 305.275(3).2 Unless an alternative basis for jurisdiction is found under ORS 305.288, the

court must dismiss an appeal of a residential property’s valuation if that value was not first

appealed to BOPTA. Gray v. Multnomah County Assessor, TC 4810, WL 933072 at *1 (Or Tax

Apr 8, 2008). ORS 305.288 provides two alternative bases for jurisdiction over appeals of real

market value: (1) where the tax roll real market value of certain dwellings differs by at least 20

percent from the correct real market value, and (2) where a party has “good and sufficient cause”

for failing to pursue the statutory right of appeal. ORS 305.288(1),(3).

Here, Plaintiffs do not dispute that they failed to appeal to BOPTA. Therefore, the court

must dismiss their Complaint unless it has jurisdiction under ORS 305.288. See Gray, WL

933072 at *1.

Plaintiffs respond to Defendant’s motion to dismiss with three allegations. First,

Plaintiffs allege that they did not have a reasonable amount of time to “respond to BOPTA.”

(Ptfs’ resp at 1.) Second, Plaintiffs allege that on January 3, 2017, court staff “confirmed that

Plaintiff should proceed with filing Complaint.” (Id.) Third, Plaintiffs argue that “they qualify

for an appeal due to the fact that the property is residential, and the difference between the real

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

FINAL DECISION OF DISMISSAL TC-MD 170017G 2 market value asserted and the real market value shown on the assessment roll is 20 [percent] or

greater.” Plaintiffs’ three allegations are addressed in turn below.

A. Reasonable Time to File BOPTA Appeal

Plaintiffs made the following allegation in their response to Defendant’s motion to

dismiss:

“The 2016–2017 Account Summary issued by Deschutes County was dated 12/11/16 and received by Plaintiff December 19th. A reasonable amount of time was not provided for Plaintiff to respond to BOPTA.”

(Ptfs’ resp at 1.) Plaintiffs’ argument is that they failed to appeal to BOPTA because they did

not receive the “Account Summary” until December 19, 2016.

This court has jurisdiction under ORS 305.288(3) where a taxpayer had “good and

sufficient cause” for failing to pursue the statutory right of appeal. As defined by

ORS 305.288(5)(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.”

This court has previously held that “[f]ailing to receive a property tax statement * * *

does not excuse a taxpayer from failing to timely appeal to the county board.” Pliska v.

Multnomah County Assessor, TC-MD 000912E, WL 33233813 (Or Tax M Div Nov 9, 2000).

Owners of real property are presumed to know that taxes are assessed on their property each

year. ORS 312.216(1) (stating presumption of notice where property subject to tax foreclosure);

see also ORS 311.250 (stating failure of taxpayer to receive tax statement by October 25 shall

not invalidate assessement). It is the taxpayers’—not the county assessor’s—duty to investigate

FINAL DECISION OF DISMISSAL TC-MD 170017G 3 if the taxpayer does not receive the property tax statement issued each October. Gordon v. Dept.

of Rev., 12 OTR 288, 290 (1992). Neither lack of knowledge nor inadvertence with respect to a

property tax assessment and the appeal procedure constitutes good and sufficient cause for

failing to pursue an appeal to BOPTA. See ORS 305.288(5)(b). No circumstance can qualify as

good and sufficient cause unless it is “beyond the control of the taxpayer, or the taxpayer’s agent

or representative.” Id.

Here, the fact that Plaintiffs owned property in Oregon was sufficient to notify them that

taxes would be assessed each year regardless of when they received documentation of that

assessment. If they did not receive their October tax statement, it was their responsibility to

contact Defendant. See Gordon, 12 OTR at 290. Plaintiffs’ choice not to investigate sooner was

not a circumstance beyond their control, and is not “good and sufficient cause” for failing to

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Related

Gordon v. Department of Revenue
12 Or. Tax 288 (Oregon Tax Court, 1992)

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Bluebook (online)
Walker v. Deschutes County Assessor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/walker-v-deschutes-county-assessor-ortc-2017.