Picker v. Dept. of Rev.

Summary

The Oregon Supreme Court affirmed the Tax Court’s dismissal of the Pickers’ appeal, holding that the taxpayers failed to establish the statutory exception of undue hardship and that the term “undue hardship” under ORS 305.419(3) is limited to financial hardship caused by payment of the tax. The court reasoned that the burden of proof lies with the taxpayer and that the Tax Court’s requirement for additional documentation was proper.