BALMER, J.
Taxpayer in this personal income tax case appeals from a judgment that the Oregon Tax Court entered after taxpayer had appealed to that court from an opinion and order of the defendant Department of Revenue (the department). ORS 305.445. Taxpayer failed to file income tax returns for the tax years 1983 through 1993, and the department assessed taxes, interest, and penalties for those years. Following trial and post-trial briefing, the Tax Court affirmed...
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