
    Argued and submitted October 14,
    judgment of Oregon Tax Court affirmed October 28, 1999
    Chester S. KURZET and Louise Jayne, Appellants, v. DEPARTMENT OF REVENUE, Respondent.
    
    (OTC 3866; SC S43936)
    988 P2d 376
    Louise Jayne, Portland, appellant pro se, argued the cause and filed the briefs for appellants.
    Jerry Bronner, Assistant Attorney General, Salem, argued the cause for respondent. With him on the brief was Hardy Myers, Attorney General.
    Before Carson, Chief Justice, and Gillette, Van Hoomissen, Durham, Leeson, and Riggs, Justices.
    
    
      
       Kulongoski, J., did not participate in the consideration or decision of this case.
    
   MEMORANDUM OPINION

The judgment of the Oregon Tax Court is affirmed. ORS 305.765; Atkins v. Dept. of Rev., 320 Or 713, 894 P2d 449 (1995), cert den 516 US 1042 (1996).  