The right of the State Tax Commission to enforce obedience to its order is fixed and is not destroyed by the lapse of time within which in the first place the duty ought to have been done. State ex rel. Taggart v. Holcomb, 1910, 81 Kan. 879, 106 P. 1030, 1032, 28 L.R.A., N.S., 251; People ex rel. Ahlschlager v. Board of Review of Cook County, 1933, 352 Ill. 157, 185 N.E. 248, 87 A.L.R. 520, 527; State ex rel. Smith v. Smith, 1952, 197 Or. 96, 252 P.2d 550. Mandamus will lie to compel a county board, or officer, to adjust the tax books of the county to conform to the order of the State Tax Commission. 61 Corpus Juris 758, § 983(f); State ex rel. Thompson v. Dirckx, 1928, 321 Mo. 345, 11 S.W.2d 38; People ex rel. State Board of Equalization v. Pitcher, 1916, 61 Colo. 149, 156 P. 812; State ex rel. Smith v. Smith, 1952, 197 Or. 96, 252 P.2d 550; Utah Oil Refining Co. v. Hendrix, 1952, 72 Idaho 407, 242 P.2d 124.

Subsequently, this court has followed Perry on several occasions. See, e.g., Stowe v. School Dist. No. 8-C, 240 Or 526, 528, 402 P2d 740 (1965); Linklater v. Nyberg, 234 Or 117, 120, 380 P2d 631 (1963); Huffman v. Alexander, 197 Or 283, 333, 253 P2d 289 (1953); State ex rel. v. Smith et al., 197 Or 96, 126, 252 P2d 550 (1953); State ex rel v. Newbry et al., 196 Or 331, 337, 248 P2d 840 (1952); Oregon State Grange v. McKay, 193 Or 627, 631, 239 P2d 834 (1952) (illustrating proposition). However, none of those cases purported to analyze this court's statement in Perry beyond citing it.

The Tax Court held that ORS 311.205 did not apply and was restricted to the correction of clerical and mechanical errors made by the officer in charge of the rolls. Since the decision of this court in State ex rel v. Smith et al, 197 Or. 96, 252 P.2d 550 (1953), ORS 311.205 and its predecessors have been interpreted to mean that clerical errors may be corrected, but that errors in the determination of the true cash value of the property assessed can be corrected only through the appellate process. In fact, the 1977 Legislature amended ORS 311.205 to define the types of clerical errors which may be corrected, and specifically stated that errors in valuation judgment are not included. The legislative history shows that the defendant itself considered ORS 311.205 to be restricted to clerical errors.

The question should be settled in the interest of effective appellate court administration. (See Almassy v. Los Angeles County CivilService Com., 34 Cal.2d 387, 390 [ 210 P.2d 503]; Walling v. Mutual Wholesale Food Supply Co., 141 F.2d 331, 334-335; People ex rel. Wallace v. Labrenz, 411 Ill. 618 [ 104 N.E.2d 769, 772]; State ex rel. Smith v. Smith, 197 Or. 96 [ 252 P.2d 550, 563]; 103 U. of Pa. L. Rev. 772, 783, 787-793; 132 A.L.R. 1185, 1186.)

[1.] After the county board of equalization has completed its tasks and returned the rolls, pursuant to ORS 309.130, subsection (1) of ORS 311.205 grants authority to the officer having charge of the rolls (initially the county assessor, followed by the tax collector, in most counties) to elect to correct the rolls upon discovering "errors or omissions of any kind therein, * * *" (with the concurrence of the assessor or of the Department of Revenue, as the case may require). The Supreme Court construed the words, "of any kind," in the case of State ex rel. v. Smith et al., 197 Or. 96, 252 P.2d 550 (1953), holding that this broad language "expands the power to correct the record beyond the limitations of mere clerical errors." ( 197 Or at 108, 252 P.2d at 555.)

Perry was later followed in a number of cases. See, e.g., State ex rel. v. Newbry et al., 196 Or 331, 337, 248 P2d 840 (1952) ("[W]e shall determine the case on the merits, even though it be moot[.] * * * We are moved to do so by the general public interest."); State ex rel. v. Smith et al., 197 Or 96, 126, 252 P2d 550 (1953) ("Even if we assume, arguendo, that the Company's tax payment did, in fact, render the present controversy moot, we are, nonetheless, moved to a determination of the cause because of the evident general public interest in the result."); Linklater v. Nyberg, 234 Or 117, 120, 380 P2d 631 (1963) ("[N]othing remains for the writ to operate upon and the case in that sense has become moot. * * * Be that as it may, there is a question here of sufficient general public interest to warrant its consideration and decision."); Stowe v. School Dist. No 8-C, 240 Or 526, 528, 402 P2d 740 (1965) ("It is apparent from the facts that the issue is, in reality, moot. Because of the public nature of the question presented and the likelihood that it will recur we will decide the case.")

"`As was pointed out in Tasea Investment Corp. v. Dale, 222 Md. 474, 160 A.2d 920 (1960) and in Murray v. Fishman Construction Co., 241 Md. 538, 217 A.2d 357 (1966), the trial court, besides requiring the party, who moves to set aside an enrolled judgment, to prove that he is acting in good faith and with diligence and that he has a meritorious defense, should also require a showing of such facts and circumstances as will establish the fraud, mistake or irregularity allegedly used to obtain the judgment sought to be vacated. "`* * * A mere error, which in legal parlance generally connotes a departure from truth or accuracy, State ex rel. Smith v. Smith, 252 P.2d 550, 555 (Ore. 1953) and Gronseth v. Mohn, 234 N.W. 603, 604 (S.D. 1931), is certainly not an irregularity (under Rule 625), which is usually defined as the doing or not doing of that, in the conduct of a suit at law, which, conformable with the practice of the court, ought or ought not to be done. State v. Lazarus, 65 S.E. 270, 272 (S.C. 1909); State ex rel. Caplow v. Kirkwood, 117 S.W.2d 652 (Mo. 1938); Babb v. City of Wichita, 241 P.2d 755 (Kan. 1952); Black's Law Dictionary (4th Ed.).

"`As was pointed out in Tasea Investment Corp. v. Dale, 222 Md. 474, 160 A.2d 920 (1960) and in Murray v. Fishman Construction Co., 241 Md. 538, 217 A.2d 357 (1966), the trial court, besides requiring the party, who moves to set aside an enrolled judgment, to prove that he is acting in good faith and with diligence and that he has a meritorious defense, should also require a showing of such facts and circumstances as will establish the fraud, mistake or irregularity allegedly used to obtain the judgment sought to be vacated. "`* * * A mere error, which in legal parlance generally connotes a departure from truth or accuracy, State ex rel. Smith v. Smith, 252 P.2d 550, 555 (Ore. 1953) and Gronseth v. Mohn, 234 N.W. 603, 604 (S.D. 1931), is certainly not an irregularity (under Rule 625), which is usually defined as the doing or not doing of that, in the conduct of a suit at law, which, conformable with the practice of the court, ought or ought not to be done. State v. Lazarus, 65 S.E. 270, 272 (S.C. 1909); State ex rel Caplow v. Kirkwood, 117 S.W.2d 652 (Mo. 1938); Babb v. City of Wichita, 241 P.2d 755 (Kan. 1952); Black's Law Dictionary (4th Ed.).

"The finding of the lower court that some of the vouchers were in the name of a corporation and some were in the name of the defendant and another person was at most no more than an indication of error in several of the vouchers. A mere error which in legal parlance generally connotes a departure from truth or accuracy, State ex rel. Smith v. Smith, 252 P.2d 550, 555 (Ore. 1953) and Gronseth v. Mohn, 234 N.W. 603, 604 (S.D. 1931), is certainly not an irregularity (under Rule 625), which is usually defined as the doing or not doing of that, in the conduct of a suit at law, which, conformable with the practice of the court, ought or ought not to be done. State v. Lazarus, 65 S.E. 270, 272 (S.C. 1909); State ex rel. Caplow v. Kirkwood, 117 S.W.2d 652 (Mo. 1938); Babb v. City of Wichita, 241 P.2d 755 (Kan. 1952); Black's Law Dictionary (4th Ed.).

"The finding of the lower court that some of the vouchers were in the name of a corporation and some were in the name of the defendant and another person was at most no more than an indication of error in several of the vouchers. A mere error, which in legal parlance generally connotes a departure from truth or accuracy, State ex rel. Smith v. Smith, 252 P.2d 550, 555 (Ore. 1953) and Gronseth v. Mohn, 234 N.W. 603, 604 (S.D. 1931), is certainly not an irregularity (under Rule 625), which is usually defined as the doing or not doing of that, in the conduct of a suit at law, which, conformable with the practice of the court, ought or ought not to be done.