BCN Telecom, Inc. v. Maine State Tax Assessor

CourtSuperior Court of Maine
DecidedOctober 5, 2015
DocketKENap-13-26
StatusUnpublished

This text of BCN Telecom, Inc. v. Maine State Tax Assessor (BCN Telecom, Inc. v. Maine State Tax Assessor) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
BCN Telecom, Inc. v. Maine State Tax Assessor, (Me. Super. Ct. 2015).

Opinion

STATE OF MAINE SUPERIOR COURT KENNEBEC, SS. LOCATION: Augusta Docket No. AP-13-26

) BCN TELECOM, INC., ) ) Petitioner, ) ORDER ON THE PARTIES' MOTIONS ) FOR SUMMARY JUDl\'IENT v. ) ) MAINE STATE TAX ASSESSOR, ) ) Respondent. ) ) ) )

BCN Telecom, Inc. ("BCN') appeals the Decision ofthe Maine Board of Tax

Appeals ("BOTA") affirming the finding of the Maine State Tax Assessor (the

"Assessor") that BCN owes service provider tax, and interest, on account ofBCN's

failure to pay said tax with respect to presubscribed interexchange carrier charges

("PICCs"). Both parties have moved for summary judgment regarding the following two

issues: 1) are PICCS included in the sale price of telecommunications services and

subject to the service provider tax; and 2) if so, are PICCs exempt from the service

provider tax as constituting the sale of interstate telecommunications services. For the

reasons discussed below, the Court denies the Assessor's motion for summary judgment,

grants BCN's, and holds that PICCs are not taxable under the service provider tax.

I. Factual Background

A local exchange carrier ("LEC") provides telecommunications services to

customers in a defined geographic area, or local exchange area. (Stipulation of Facts ("Stipp.")~ 1.) The telecommunications service provided by aLEC is commonly known

as "local service" or "local exchange service," and is a telecommunications service

within the local exchange area. '(!d. at~ 2.) A competitive local exchange carrier

("CLEC") is aLEC providing local exchange service that competes with incumbent local

exchange carriers ("ILECS") and other CLECs. 1 (!d. at~ 5.) An interexchange carrier

("IXC") provides telecommunications services between exchange areas, and is

commonly known as long distance service. (Id. at~ 6.)

BCN is a privately held telecommunications service provider company with its

principal offices in New Jersey. (Id. at~ 12.) BCN is a reseller of telecommunications.

(!d. at~ 13.) It contracts with local and long distance carriers and resells those services to

customers in Maine and elsewhere. (!d.) On or about January 5, 2011, Maine Revenue

Services (":MR.S") sent BCN an Intent to Audit letter. (See id. at~ 17.) Thereafter, MRS

began an audit ofBCN that covered the period of March 1, 2008 to October 31, 2011 (the

"Audit Period"). (See id. at~~ 14-16.) During this period, BCN acted as both a CLEC

and an IXC in Maine. (!d. at~ 14.)

As the audit progressed, it became clear that the primary issue concerned the

taxation ofPICCs and whether they were subject to service provider tax pursuant to 36

M.R.S. §§ 2551-2560. (See id. at~ 18.) During the Audit Period, BCN paid PICCs to

long distance carriers from whom BCN purchased long distance services for resale. (!d.

at~ 15.) BCN did not charge PICCs to any other carriers. (See id. at~ 16.)

1 An ILEC is aLEC that was operating before February 8, 1996, i.e. the breakup of AT&T. (Id. at~ 3.) An ILEC owns and maintains the telephone lines and poles and other infrastructure within its local exchange area. (Id. at~ 4.) This infrastructure includes the "local loop," which is the line from the customer's premises to the office of the LEC. (!d.)

2 During the Audit Period, BCN had Maine customers with only local service,

Maine customers with long distance service, and Maine customers with both local and

long distance service. '(Id. at~ 30.) BCN charges a fixed monthly rate for local service.

(Id. at~ 31.) BCN charges for long distance usage, charging per call and per minute. (Id.

at~ 32.) BCN charges long distance rates in Maine for interstate calls (calls terminating

outside of Maine), as well as intrastate long distance calls (calls terminating within

Maine). (Id. at~ 33.) BCN only charges PICCs to its business customers with multiple

long distance lines? (Jd. at~ 35.) When a customer has long distance service through

BCN, BCN establishes and maintains network readiness so that the customer has access

to long distance service and can make a long distance call. (Resp.'s S.M.F. ~ 84.)

The PICCs are charged as a monthly per line charge, which is typically a monthly

rate of $2.95 per long distance line. (Stipp.~ 38.) BCN charges PICCs even if the

customer does not make any long distance calls on that line during the month. (Jd. at~

39.) The amount ofPICCs charged by BCN are discretionary, although there is a

statutory ceiling on the amount that can be charged. (Resp.'s S.M.F. ~ 25.) BCN

determines the amount it will charge for PICCs based on maintaining a certain level of

profit, evaluating and responding to price increases charged to BCN, and determining

how to best pass that along to the customer. (Id. at~ 26.) BCN's default position is to

charge PICCs unless it has been negotiated out of the agreement with the customer. (ld.

at~ 27.) PICCs are listed on BCN's bills under "Other Charges," which, along with

"Customer Level Charges" are competitive charges that can be negotiated out of a

customer's agreement with BCN. (Id. at~~ 29-30.) Only the amounts reflected in the

2 BCN did not charge PICCs to residential customers or customers that only had local service because it is not permitted by federal law. (Id. at~~ 36-37.) lines that say "local" and "long distance" on BCN' s bills represent charges for

telecommunications services. (Id. at~ 31.) All of the other charges and fees on a

customer's bills are not for electronic transmissions, i.e., telecommunications services.

(Jd. at~ 32.) If a customer that is charged PICCs does not pay the charges, then BCN has

the option of terminating that customer's service. (Id. at~ 34.)

The Federal Communications Commission ("FCC") created the PICC, allowing

carriers to recover a portion of the interstate local loop cost either from the IXC or from

the end-user. (Stipp.~ 19.) During the audit, regulatory counsel for BCN sought and

received input concerning the jurisdictional nature ofPICCs from the FCC. (Id. at~ 20.)

The FCC explained that it would not get involved in disputes between carriers and state

regulatory bodies, but provided "some general advice as to universal service contribution

requirements related to certain fees or end user charges, like [PICCs]." (Exhibit 5 to

Stipp.) The general advice was: "[c]onsistent with [FCC] precedent, PICC charges are

considered interstate revenues. They allow a carrier to recover a portion of the interstate

local loop cost either from the interexchange carrier or from the end-user customer when

the customer is not presubscribed to an interexchange carrier." (Id.)

The Assessor concluded that PICCs were not exempt from service provider tax

and assessed BCN $41,296.96 in tax on the revenue received from PICCs and $7,778.60

in interest, for a total amount of $49,075.56. (Jd. at~~ 21-22.) Pursuant to 36 M.R.S. §

151, BCN sought reconsideration of the Assessment in a letter dated May 2, 2012. (Id. at

~ 23.) The Assessment was upheld and an additional $2,036.54 in additional interest

accrued for a total then due of$51,112.10. (Id. at~ 24.) ·BCN sought review ofthat

decision through a written statement of appeal to Maine Board of Tax Appeals ("BOTA")

4 dated October 22, 2012. (!d. at ,-r 25.) In a Decision dated April 24, 2013, BOTA

concluded that PICCs were not exempt from service provider tax and upheld the

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BCN Telecom, Inc. v. Maine State Tax Assessor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bcn-telecom-inc-v-maine-state-tax-assessor-mesuperct-2015.