Statute Annotations › Oregon › Or. Rev. Stat. § 305.275

Or. Rev. Stat. § 305.275

Appeals of tax decisions and administrative exhaustion: the cases that interpreted this section

Jurisdiction
Oregon
Case notes
327
Cited in passing
172
Citing cases indexed
712
Case dates
1978–2026
Screened through
2026-05-15
Checked for later law changes
2026-10-21
Courts' treatment: live
No reviewed case has held this section invalid, preempted, superseded or repealed.
This reflects what the reviewed cases said, not legislative action: a later amendment or repeal by the legislature would not appear here unless a reviewed case discussed it.

499 citing cases reviewed of 712 in the citation index: 327 interpreted the section (annotated below), 172 cited it only in passing. Cases filed after 2026-05-15 may not have been reviewed yet.

Have a situation under Or. Rev. Stat. § 305.275?

These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.

Standing to appeal

Section 305.275(1) requires a tax appeal to have a possible practical effect on the taxpayer’s tax liability for the Tax Court to have jurisdiction.

Noble v. Wallowa County Assessor · filed 2016-08-03(1)

The court lacks jurisdiction where the relief requested by a taxpayer would not affect tax liability. See ORS 305.275(1) (2015); FedEx Ground Package System, Inc. v. Dept. of Rev., 20 OTR 547, 549 (2012) (“This court has consistently held that where there is no possibility of a practical effect on the tax liability of a taxpayer, a case is rendered non-justiciable such that the court is divested of jurisdiction.”) Because the stipulated values result in no change to the 2015-16 assessed value and there is no compression, the court lacks jurisdiction over Plaintiffs’ 2015-16 tax year appeal of the subject property.
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Section 305.275(1) does not give the Tax Court jurisdiction when the requested relief would not affect tax liability.

Deschutes County Assessor v. WWC Investments, LLC · filed 2017-02-06(1)

The court lacks jurisdiction where the relief requested by a party would not affect tax liability.
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Section 305.275(1)(a)(B) requires a taxpayer to be aggrieved; a complaint seeking an increase in the property's real market value does not establish aggrievement.

Metke v. Jefferson County Assessor · filed 2016-09-07(1)(a)(B)

The court also notes that Plaintiff’s Complaint seeks an increase to the real market value of the subject property. As pled, Plaintiff would not be aggrieved and the court would not have jurisdiction pursuant to ORS 305.275(1)(a)(B).
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Section 305.275(1)(a) requires a taxpayer appealing a property value to be aggrieved: the requested relief must result in tax savings.

Mountain Park Office Campus LLC v. Clackamas County Assessor · filed 2018-02-06(1)(a)

This court has held that a taxpayer appealing to this court must be “aggrieved.” See ORS 305.275(1)(a); Kaady v. Dept. of Rev., 15 OTR 124, 125 (2000). In the property value context, a taxpayer is aggrieved if its requested relief will result in “tax savings”–that is, if the real market value is less than the maximum assessed value or if the property tax account is in compression.
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Section 305.275(1)(a) requires a person appealing a tax determination to show an injury that gives them an interest in the outcome distinct from the general public’s.

Seneca Sustainable Energy, LLC v. Dep't of Revenue · filed 2018-11-08(1)(a)

That is, all that is required to prove aggrievement under ORS 305.275(1) is a showing that the person suffered an injury or wrong that creates a private interest in the outcome of the matter that is different from that of a member of the general public.
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When an assessor withdraws land from open space classification, the withdrawal is the act that affects the taxpayer’s property and permits an appeal challenging the values used to calculate the additional assessment.

River Vale Limited Partnership v. Dept. of Rev. · filed 2021-03-10(1)

The requisite act occurred only when the assessor withdrew the Property from classification.
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A county assessor lacks standing to appeal a board of property tax appeals order that sustains the tax roll value because the assessor is not aggrieved.

King v. Columbia County Assessor · filed 2022-06-30(4)

A county assessor may not appeal from a board of property tax appeals order sustaining the tax roll value because the assessor is not aggrieved and lacks standing to appeal the board order.
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Section 305.275 applies to appeals, so its aggrievement requirement does not bar a party from requesting a valuation determination under ORS 305.287 in an existing appeal.

Paradigm Bend LLC v. Deschutes County Assessor · filed 2018-08-13

Plaintiff’s challenges based on aggrievement under ORS 305.275 and timeliness under ORS 305.280(4) are not well taken. Each of those statutes, by its terms, applies to “appeals.” As the Supreme Court in Village I explained, ORS 305.287 does not authorize an “appeal.”4 Thus, neither statute applies to the relief requested under ORS 305.287.
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Section 305.275(1)(a) requires a taxpayer to be aggrieved; a proposed value that would not change the property tax does not satisfy that requirement.

Nguyen v. Multnomah County Assessor · filed 2018-12-11(1)(a)

Because properties are taxed on the lesser of the real market value or the maximum assessed value, even if the court agreed with his values, his property tax would not change. Or in other words, Plaintiff would not meet the legal requirement that he be aggrieved as required by ORS 305.275(1)(a).
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Section 305.275(1)(a) requires a taxpayer to be aggrieved; seeking an exemption that would eliminate the taxpayer’s property tax liability satisfies that requirement.

Lauer v. Grant County Assessor · filed 2020-12-01(1)(a)

To begin, the court briefly addresses Defendant’s argument that Plaintiff is not aggrieved, as required by ORS 305.275(1)(a). ... Here, Plaintiff seeks a property tax exemption, which would eliminate his tax liability on the subject property. He has adequately demonstrated that he is aggrieved.
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Section 305.275(1) requires a property tax appellant to be aggrieved; a possible future tax increase does not satisfy that requirement while the current assessment remains unchanged.

Murray v. Wasco County Assessor · filed 2018-08-14(1)

Since the potential disqualification from farm use special assessment has not occurred, Plaintiff’s tax obligation remains theoretical. Thus, at the time Plaintiff filed the Complaint he was not aggrieved and did not have standing to appeal his property tax assessment.
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Section 305.275 requires a taxpayer to be personally aggrieved to maintain an action in the Tax Court; a general concern that the department follow the law is insufficient.

Christensen II v. Dept. of Rev. · filed 2018-09-07

If taxpayer is not aggrieved, he may not maintain an action in the court.
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Section 305.275(1) requires a taxpayer claiming aggrievement to show a wrong that creates a private interest in the outcome.

4310 Building LLC v. Multnomah County Assessor · filed 2019-09-30(1)

Thus, aggrievement requires both that there be a “wrong” and that the wrong “create[] a private interest.”
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A taxpayer is not aggrieved under section 305.275 when the requested reduction in real market value would have no immediate effect on the taxpayer’s property tax obligation.

Swanek v. Lane County Assessor · filed 2021-03-03(1)(a)

Generally, where a taxpayer’s requested real market value has no immediate impact on the taxpayer’s property tax obligation, the taxpayer is not aggrieved under ORS 305.275. Here, Plaintiff’s requested real market value for each of the accounts appealed would have no impact on assessed value. Plaintiff’s real market value claim is dismissed.
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Section 305.275(1)(a) requires a taxpayer appealing a property value to show that the requested change would produce tax savings.

Wall v. Multnomah County Assessor · filed 2018-09-18(1)(a)

As Defendant correctly stated in its Reply, this court has interpreted the “aggrievement” requirement in ORS 305.275(1)(a) to mean that the taxpayer will realize tax savings from the requested change in value. ... As a result, the court agrees with Defendant that Plaintiffs are not aggrieved under ORS 305.275(1)(a) for any of the three tax years based on their requested real market values.
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Section 305.275 requires a taxpayer appealing a Department of Revenue action to show that the taxpayer is aggrieved by an act, order, or omission.

Godard v. Dept. of Rev. · filed 2022-04-07(1)(a)(A)

Any person may appeal to this court if they are “aggrieved by and affected by an act, omission, order, or determination of * * * [t]he Department of Revenue in its administration of the revenue and tax laws of this state.” ORS 305.275(1)(a)(A). Plaintiff appealed Defendant’s assessment for the 2018 tax year and is aggrieved by that assessment. Plaintiff has not identified any notices or appealable actions taken by Defendant for any other tax years. If Plaintiff wishes to challenge such actions, Plaintiff must either file a new complaint or seek leave to amend his complaint. Any complaint must show how Plaintiff is aggrieved by an act, order, or omission of Defendant.
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Section 305.275(1) requires a taxpayer seeking correction of assessment records to show that the data are wrong and that correcting them is necessary to remedy a pecuniary harm.

Linstrom v. Dept. of Rev. · filed 2023-12-05(1)

To file a law suit in this court, a taxpayer must be “aggrieved” by an action or omission of an assessor or other taxing authority, and the action or omission must “affect” the taxpayer’s property. ORS 305.275(1). Oregon Supreme Court has held that these requirements mean that a taxpayer must be “more than just dissatisfied” by the action or omission. NW Medical Lab. V. Good Samaritan Hospital, 309 Or 262, 268, 786 P2d 718 (1990). The taxpayer must show a “pecuniary harm,” which typically means showing that “property tax bills * * * were improperly inflated.”
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Section 305.275(1)(a) requires a taxpayer appealing property value to be aggrieved: the requested reduction in real market value must reduce property tax liability.

Nichols v. Curry County Assessor · filed 2023-12-11(1)(a)

ORS 305.275(1)(a) requires a taxpayer to be “aggrieved,” which this court has interpreted to mean that the requested reduction in RMV, if granted, would reduce the property tax liability.
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Section 305.275 requires a person to be aggrieved to appeal; seeking a change in property classification without showing an effect on value does not establish standing.

Calcagno Fresh Farms, LLC v. Morrow County Assessor · filed 2025-09-25

Under that statutory text, a person must be “aggrieved” to appeal. ... Plaintiff has not established either a statutory right to appeal the subject’s industrial classification or its own standing to bring such a claim, and Plaintiff’s concerns about the court’s jurisdiction are unfounded.
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Section 305.275(1)(b) does not give a person standing to appeal an assessor’s action if the person acquired the affected property only after the action occurred.

Petite Shangri-La LLC v. Multnomah County Assessor · filed 2026-03-02(1)(b)

An interest that is indirect, contingent, or acquired after the challenged action is insufficient.
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A taxpayer is aggrieved under section 305.275(1)(a) only if reducing the property's real market value would reduce the taxpayer's property tax liability.

Mednansky v. Curry County Assessor · filed 2024-03-07(1)(a)

However, under any reasonable allocation, Plaintiff is not aggrieved because the resulting real market value would still exceed the subject property’s maximum assessed value.
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Section 305.275(1)(a) requires a taxpayer to be aggrieved by an assessor’s determination; speculative effects of a property value on financing and construction do not establish aggrievement.

Broken Trail LLC v. Deschutes County Assessor · filed 2024-09-06(1)(a)

Instead, Plaintiffs focus on other alleged harms associated with an understated RMV: their ability to get a loan and respond to questions from their builder. Those harms are speculative at this point and apart from Plaintiffs’ tax liability. Plaintiffs have therefore failed to demonstrate that they are aggrieved within the meaning of ORS 305.275(1)(a).
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Section 305.275(1)(a) requires an appealable act, omission, order, or determination for the tax years at issue; potential additional taxes from a later disqualification do not make a taxpayer aggrieved for earlier years.

Holmes Family Trust v. Multnomah County Assessor · filed 2025-12-16(1)(a)

Plaintiff’s appeal of the 2019-20 to 2023-24 tax years is dismissed because Plaintiff is not aggrieved under ORS 305.275(1)(a) for those years.
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Section 305.275(1)(a) requires a plaintiff to be aggrieved; seeking to overturn Measure 50 and related statutes does not meet that requirement.

Moore v. Jackson County Assessor · filed 2024-07-24(1)(a)

First, as explained above, in seeking to overturn Measure 50 and related statutes, Plaintiff is not aggrieved as required by ORS 305.275(1)(a).
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Section 305.275(1)(a)(A) requires a taxpayer to identify an act, omission, order, or determination by the Department of Revenue that aggrieves them before appealing.

Eriksen v. Dept. of Rev. · filed 2025-10-02(1)(a)(A)

Plaintiff’s appeal for the tax period ending December 31, 2023, is dismissed because Plaintiff has not identified any act, omission, order or determination by Defendant for that period. Plaintiff is not, therefore, aggrieved under ORS 305.275(1)(a) with respect to the tax period ending December 31, 2023.
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A taxpayer who receives a notice of assessment may appeal even if the only item challenged was not adjusted by the Department of Revenue.

Korkeakoski v. Dept. of Rev. · filed 2025-04-07(1)(a)(A)

Although it is unusual – perhaps unprecedented – for a taxpayer to challenge only an item that the department never adjusted, such an appeal appears to be permissible when taxpayer has received a notice of assessment.
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A person appealing to the Magistrate Division must be aggrieved; a value reduction that produces tax savings satisfies that requirement.

Frankel v. Multnomah County Assessor · filed 2012-10-24(1)(a)

Defendant agreed to stipulate to that value for that tax year because Plaintiff satisfied the requirement under ORS 305.275(1)(a) that the person appealing to the Magistrate Division of the Oregon Tax Court be “aggrieved.” Namely, the amount of the value reduction exceeded the 20 percent statutory threshold provided in ORS 305.288(1)(b), and the reduction would generate tax savings for the 2009-10 tax year.
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Notes 301–327 of 327, oldest cases first.

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