Chavez-Tena v. Department of Revenue

CourtOregon Tax Court
DecidedApril 30, 2012
DocketTC-MD 111015C
StatusUnpublished

This text of Chavez-Tena v. Department of Revenue (Chavez-Tena v. Department of Revenue) 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
Chavez-Tena v. Department of Revenue, (Or. Super. Ct. 2012).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Income Tax

FILEMON CHAVEZ-TENA, ) ) Plaintiff, ) TC-MD 111015C ) v. ) ) DEPARTMENT OF REVENUE, ) State of Oregon, ) ) Defendant. ) DECISION

Plaintiff has appealed adjustments made by Defendant to his state tax returns for 2008

and 2009. Trial was held in Salem on April 3, 2012. Plaintiff appeared on his own behalf, aided

by two Spanish language interpreters. Defendant was represented by Kyle Quiring, Tax Auditor,

Oregon Department of Revenue.

I. STATEMENT OF FACTS

Plaintiff filed Oregon tax returns for 2008 and 2009 on August 30, 2010. Defendant

issued a Notice of Deficiency for the 2008 tax year on December 20, 2010, and a Notice of

Deficiency Assessment on February 15, 2011. Defendant issued a Notice of Deficiency for the

2009 tax year on November 9, 2010. Plaintiff subsequently filed an amended 2009 Oregon

return November 22, 2010. Defendant issued a Notice of Deficiency Assessment for the 2009

tax year on January 19, 2011. For reasons not entirely clear the court, Defendant then issued

Plaintiff a refund based on Plaintiff‟s amended 2009 Oregon return on June 27, 2011.1

Plaintiff claimed himself and six other individuals as dependents (for a total of seven

dependents) on both returns (2008 and 2009). The dependents Plaintiff claimed were his mother

1 It is likely that Defendant was processing the assessment for 2009 following the earlier deficiency, and that the 2009 amended return Plaintiff filed was processed separately and ultimately generated a refund that Defendant now seeks to reclaim by disallowing the two dependents and changing Plaintiff‟s filing status to single.

DECISION TC-MD 111015C 1 and father, two nephews, and two godchildren. All of those individuals live in Mexico in a

house owned by Plaintiff. Plaintiff also chose a filing status of head of household for both tax

years.

Defendant allowed only one dependent (Plaintiff) for 2008 and three dependents

(Plaintiff and his two parents) for 2009. Because Defendant disallowed all of the dependents

(other than Plaintiff) on Plaintiff‟s 2008 return, Defendant changed Plaintiff‟s 2008 filing status

from head of household to single.

Plaintiff has appealed those adjustments to this court, requesting that the court allow all

claimed dependents on his returns for both tax years. If the court allows any dependents,

Plaintiff would be allowed the head of household filing status as well.

Defendant has asked the court to uphold the assessment for 2008 and to allow an

additional deficiency for 2009 in the amount of $672. (See Def‟s Ans at 1; Def‟s Ex B-1.) That

deficiency would follow from disallowing the two dependent exemptions Defendant believes

were erroneously allowed on the amended 2009 return, and changing Plaintiff‟s 2009 filing

status to single.

II. ANALYSIS

As this court has previously noted, “[t]he Oregon legislature intended to make Oregon

personal income tax law identical to the Internal Revenue Code (IRC) for purposes of

determining Oregon taxable income, subject to adjustments and modifications specified in

Oregon law. ORS 316.007.” Ellison v. Dept. of Rev., TC-MD No 041142D, WL 2414746 at *6

(Sept 23, 2005). As a result, the legislature adopted, by reference, the federal definition for

dependents, including those allowed under section 152 of the Internal Revenue Code (IRC).

///

DECISION TC-MD 111015C 2 IRC section 152(a) generally defines dependent to include a qualifying child, or a

“qualifying relative.” Parents and nephews are “qualifying relatives,” but persons not related by

blood or marriage--e.g., godchildren--are not. IRC § 152(d)(2) (defining a qualifying relative as

“an individual [who] bears a relationship to the taxpayer described in th[at] paragraph,” the list

of which includes individuals generally related by blood or marriage including the taxpayer‟s

children and descendents of such children, brothers, sisters, stepbrothers and stepsisters, a father

or mother, stepfather or stepmother, children of a brother or sister of the taxpayer and the various

in-laws). Thus, Plaintiff has four qualifying relatives. Additionally, “[t]he term „dependent‟

does not include an individual who is not a citizen or national of the United States unless such

individual is a resident of the United States or a country contiguous to the United States.” IRC

152(b)(3). Plaintiff‟s relatives in Mexico, a country contiguous to the United States, meet that

requirement.

To claim a qualifying relative as a dependent, a taxpayer must provide more than one-

half of the individual‟s support for the calendar year. IRC § 152(d)(1)(C) (requiring that the

taxpayer claiming the dependent “provides over one-half of the individual‟s support for the

calendar year”). Moreover, a taxpayer must not only provide over one-half of the support, but be

able to prove that support.

“In all proceedings before the judge or a magistrate of the tax court and upon appeal

therefrom, a preponderance of the evidence shall suffice to sustain the burden of proof. The

burden of proof shall fall upon the party seeking affirmative relief * * *.” ORS 305.427.2 This

court has previously ruled that “[p]reponderance of the evidence means the greater weight of

evidence, the more convincing evidence.” Feves v. Dept. of Revenue, 4 OTR 302, 312 (1971).

2 All references to the Oregon Revised Statutes (ORS) are to 2009.

DECISION TC-MD 111015C 3 See also Riley Hill General Contractor v. Tandy Corp., 303 Or 390, 394, 737 P2d 595 (1987)

(noting that the Latin origin of the word preponderance “translates to „outweigh, be of greater

weight,‟ ” and “is generally accepted to mean the greater weight of evidence”).

Defendant is willing to accept that Plaintiff sent approximately $7600 to his family in

Mexico in 2008 and approximately $4181 in 2009. While Defendant‟s representative stated at

trial that he respected Plaintiff for helping his family, he did not believe Plaintiff should be

allowed to claim any of the dependents in Mexico because there is no way to determine from the

evidence presented whether Plaintiff satisfies the support test in IRC section 152. The court

agrees.

Plaintiff submitted a sworn statement given by his parents in Mexico which indicates that

they (the parents) and the four children living in the home with them “depend economically” on

their son--Plaintiff in this case--and that Plaintiff has “frequently” sent money to them for

housing, food, clothing and medical expenses for the last 11 years. (Ptf‟s Ex 1.) However,

Plaintiff testified that he has no receipts for the family‟s household expenses in Mexico because

merchants in that country generally do not give receipts. Moreover, when questioned by the

court, Plaintiff was only able to estimate the family‟s likely monthly grocery budget, testifying

that he believed they spent approximately $400 per month on food. Additionally, Plaintiff‟s

home in Mexico where his relatives live sits on 24 acres of land and Plaintiff testified that the

family grows vegetables (primarily corn, beans and squash) for their own personal consumption.

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Related

Riley Hill General Contractor, Inc. v. Tandy Corp.
737 P.2d 595 (Oregon Supreme Court, 1987)
Feves v. Department of Revenue
4 Or. Tax 302 (Oregon Tax Court, 1971)

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