
    Argued and submitted January 29,
    affirmed July 9,
    reconsideration denied August 20, 1985
    STAN WILEY, INC., Appellant, v. DEPARTMENT OF REVENUE et al, Respondents.
    
    (TC 1949; SC S30939)
    702 P2d 1082
    Honorable Samuel B. Stewart, Judge (Order Allowing Judgment) Honorable Edward H. Howell, Judge Pro Tern (Judgment).
    Gile R. Downes, Portland, argued the cause for appellant. With him on the briefs was Holmes, DeFrancq & Schultz, Portland.
    Elizabeth Stockdale, Assistant Attorney General, Salem, and Joel D. Kuntz, Portland, argued the cause for respondents. With them on the brief were Gersham Goldstein, Gregory C. Newton, and Stoel, Rives, Boley, Fraser & Wyse, Portland, and James C. Wallace, Assistant Attorney General, and Dave Frohnmayer, Attorney General, Salem.
    Ray W. Shaw and Donald H. Upjohn, Salem, filed an amicus curiae brief on behalf of Oregon Association of Realtors. With them on the brief were Heltzel, Byers, Upjohn, Shaw & Williams, Salem.
    LINDE, J.
   LINDE, J.

The decision of the Oregon Tax Court is affirmed. Realty Group v. Dept. of Rev., 299 Or 377, 702 P2d 1075 (1985).  