Pilgrim Turkey Packers, Inc. v. Department of Revenue (1971)
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It could only be applied when there is proof positive that the collector has misinformed the individual taxpayer and the taxpayer has a particularly valid reason for relying on the misinformation and that it would be inequitable to a high degree to compel the taxpayer to conform to the true requirement.” Johnson v. Tax Commission, 248 Or 460, 463-64 , 435 P2d 302 (1967), quoted in Harris v. Comm., 3 OTR 440, 442 (1969); Pilgrim Turkey Packers v. Dept. of Rev., 4 OTR 498, 502…