CARSON, Justice.
The issue in this case is whether plaintiff has alleged ultimate facts sufficient to constitute a claim under Oregon Tax Court Rule 18 (TC Rule 18). Pursuant to statutory authority, the Oregon Tax Court has promulgated rules of practice and procedure (effective July 1, 1980) which rules are required to conform, as far as practical, with the "rules of equity practice and procedure in this state." ORS 305.425(3). The Tax Court has promulgated TC Rule...
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