3D Logics, LLC v. Washington County Assessor

CourtOregon Tax Court
DecidedMarch 8, 2023
DocketTC-MD 220439R
StatusUnpublished

This text of 3D Logics, LLC v. Washington County Assessor (3D Logics, LLC v. Washington County Assessor) is published on Counsel Stack Legal Research, covering Oregon Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
3D Logics, LLC v. Washington County Assessor, (Or. Super. Ct. 2023).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax

3D LOGICS, LLC, ) ) Plaintiff, ) TC-MD 220439R ) v. ) ) WASHINGTON COUNTY ASSESSOR, ) ) Defendant. ) DECISION

Plaintiff appeals Defendant’s imposition of late filing penalties for the 2018-19, 2019-20,

and 2020-21 tax years. A remote trial was held on February 3, 2023. Tiffany Logan (Logan)

appeared and testified on behalf of Plaintiff. Kelly Hall and Kathryn Vai appeared on behalf of

Defendant. Plaintiff’s Exhibits 1 to 5 and Defendant’s Exhibits A to G were admitted into

evidence without objection.

I. STATEMENT OF FACTS

The facts of this case are not in dispute. In 2017, Plaintiff registered its business with the

state, leased an office in the city of Hillsboro, applied for city permits, and made tenant

improvements in anticipation of business operations. In the same year, Plaintiff applied to

Defendant for a security alarm and the city of Hillsboro granted a certificate of occupancy after

inspecting Plaintiff’s tenant improvements.

In December 2020, Defendant became aware of Plaintiff’s business and created a

business personal property tax account in its system. In January 2021, Defendant mailed a 2021

Confidential Personal Property Tax Return (CPPR) to Plaintiff. Logan testified that Plaintiff was

not aware of its obligation to file a CPPR until receiving that notice. On June 1, 2021, Plaintiff

filed its 2021 CPPR, identifying the “date business originated in county” as March 1, 2017, and

DECISION TC-MD 220439R 1 valued the personal property at $636,088. In November 2021, Plaintiff received Defendant’s

2021-22 Personal Property Tax Statement in the mail with a real market roll value of $968,574.

(Ex 3).

In December 2021, Sterling Logan on behalf of Plaintiff, met with Defendant to discuss

the real market value of the personal property. Defendant’s representative advised Plaintiff to

file an appeal with the Board of Property Tax Appeals (BOPTA) on or before the filing deadline

of December 31st. Plaintiff filed its appeal with BOPTA and on February 18, 2022, BOPTA

mailed Plaintiff its Board Order lowing Plaintiff’s personal property value for the 2021-22 tax

year to $636,088. Plaintiff did not request BOPTA to waive the five percent late filing penalty

imposed for the 2021-22 tax year.

On June 23, 2022, Defendant mailed Plaintiff a notice of omitted property, which

included a 50 percent late filing penalty for the 2018-19, 2019-20, and 2020-21 tax years (years

in issue). Plaintiff subsequently filed the returns but did not file an application seeking a penalty

waiver either to Defendant or BOPTA. Plaintiff seeks a penalty waiver from this court.

II. ANALYSIS

The issues are whether late filing penalties were properly imposed upon Plaintiff under

ORS 308.296 and, if so, whether Plaintiff made a proper showing of good and sufficient cause

under ORS 305.422 permitting the court to waive the penalties.1

A. Taxpayers Bear the Responsibility of Filing Personal Property Tax Returns

Plaintiff acknowledges that its returns were late for the years in issue but urges the court

to consider its lack of knowledge of the filing requirement. Plaintiff points to its various

1 References to the Oregon Revised Statutes (ORS) are to the 2017 edition, which were unchanged in the 2019 edition.

DECISION TC-MD 220439R 2 business and construction applications to show that Defendant knew or should have known

Plaintiff was in business and should have sent Plaintiff notices to file returns. However, the law

places the burden on the owners of personal property to file personal property tax returns each

year. See ORS 308.290(1)(a). The statutory deadline for filing personal property tax returns was

March 15 for the years in issue. ORS 308.290(4). Taxpayers who file returns after the March 15

deadline, but on or before June 1, are subject to a five percent penalty. ORS 308.296(2).

Taxpayers who fail to file returns entirely or after August 1 are subject to a 50 percent penalty.

ORS 308.296(4). Because Plaintiff failed to file its returns for the tax years in issue until long

after the deadlines, it is subject to a 50 percent penalty.

B. Standard of Review to Waive CPPR Filing Penalties

ORS 305.422 allows the Tax Court to waive a taxpayer’s liability for all, or a portion of,

a late filing penalty “upon a proper showing of good and sufficient cause.”2 ORS 305.422 does

not further define the standard. In determining whether good and sufficient cause exists, the

court has historically used “good and sufficient cause” as defined in elsewhere in chapter 305 as

a guide, including in ORS 305.288(5)(b). See Nat'l Metallurgical Corp. v. Dept. of Rev., 7 OTR

142, 144-45 (1977), aff'd, 282 Or 317, 577 P2d 941 (1978); Wong v. Clackamas Cty. Assessor,

TC-MD 021125C, WL 21263657 at *2 (Or Tax M Div Feb 28, 2003); Lardo Bakery, LLC v.

Multnomah Cty. Assessor, TC-MD 160386R, WL 3485860 at *2 (Or Tax M Div Aug 15, 2017).

2 The court observes that the legislature has created different standards for penalty waivers of the type involved here, depending on where the request is made. ORS 308.296(8) allows a county assessor to waive late filing penalties “if the assessor finds the reasons given by the taxpayer in the application are sufficient to excuse the failure to file” along with the requirements that the taxpayer be a first-time filer and not previously been granted a waiver. In contrast, under ORS 308.296(6), BOPTA may waive the penalty “upon a proper showing of good and sufficient cause[.]” In this case, Defendant stated that they reject all requests for a waiver, because the statutory language is too ambiguous. One has to wonder if the legislature intended county assessors to forego using their discretion to waive penalties such as presented here. Nevertheless, the court has no reason to examine Defendant’s policy in this case because Plaintiff offered no evidence that it ever made a request to Defendant to waive the penalties.

DECISION TC-MD 220439R 3 ORS 305.288(5)(b) defines the term “good and sufficient cause” as follows:

“(b) ‘Good and sufficient cause’:

Free access — add to your briefcase to read the full text and ask questions with AI

Related

National Metallurgical Corp. v. Department of Revenue
7 Or. Tax 142 (Oregon Tax Court, 1977)
National Metallurgical Corp. v. Department of Revenue
577 P.2d 941 (Oregon Supreme Court, 1978)

Cite This Page — Counsel Stack

Bluebook (online)
3D Logics, LLC v. Washington County Assessor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/3d-logics-llc-v-washington-county-assessor-ortc-2023.