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LEWIS v. DEPT. OF REV.

OTC 2205; SC S32246.

728 P.2d 1378 (1986)

302 Or. 289

Jean W. LEWIS; Charles W. Niete; William E. Skortes; R.B. Gaines; Carmelia M. Wiser; Allen J. Wirfs Family Trust; Allen J. and Geraldine R. Wirfs; Sherman A. Hellerud; Stanton W. Nystrom; Elmer A. Flaming; William B. Patton; David H. Kruse; R.J. Fleskes; Gordon L. Bursell; Eddie L. Wilson; Sheila M. Nolan; Sally Foster; and Lenore M. Thomas, Appellants, v. STATE OF OREGON, Department of Revenue, Respondent.

Supreme Court of Oregon, In Banc.

Decided November 25, 1986.

Attorney(s) appearing for the Case

Carlton P. Loennig, Portland, argued the cause for appellants. With him on the brief was Barton & Loennig, Portland.

Marilyn J. Harbur, Asst. Atty. Gen., Salem, argued the cause for respondent. With her on the brief was Dave Frohnmayer, Atty. Gen., Salem.

LINDE, Justice.

Taxpayers appeal from a decision of the Oregon Tax Court affirming the assessment of taxpayers' units in a beachfront condominium, which are pooled for rentals through a common management, on the basis of their value as individual parcels of real property rather than as fractional interests in a motel.

We take a summary of the facts from the opinion of the tax court:

"Appealing plaintiffs...

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