Continental Bank v. Arizona Department of Revenue

638 P.2d 228, 131 Ariz. 6, 1981 Ariz. App. LEXIS 576
CourtCourt of Appeals of Arizona
DecidedOctober 6, 1981
Docket1 CA-CIV 4801
StatusPublished
Cited by9 cases

This text of 638 P.2d 228 (Continental Bank v. Arizona Department of Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals of Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Continental Bank v. Arizona Department of Revenue, 638 P.2d 228, 131 Ariz. 6, 1981 Ariz. App. LEXIS 576 (Ark. Ct. App. 1981).

Opinion

OPINION

FROEB, Judge.

Continental Bank filed claims with the Arizona Department of Revenue for tax refunds in the years 1974 and 1975. Both claims were denied by the Department and Continental timely protested to the Arizona State Board of Tax Appeals. The Board sustained the Department’s position as to each claim for refund. Continental then filed civil actions for each taxable year in the superior court, which were consolidated. Both parties filed motions for summary judgment. Continental’s motion was granted and the Department’s motion was denied. The Department appeals from that ruling.

Continental Bank is an Arizona corporation conducting a banking business in Arizona. In the ordinary course of its banking business, Continental obtains funds from depositors to whom it pays interest, and makes loans to borrowers to whom it charges interest. Continental’s largest single expense item is the interest it pays to depositors for the use of the funds with which to conduct its banking business. As a part of this business, it purchases and holds the debt instruments of various units of the federal, state, and local government.

Continental challenges two state tax provisions. The first involves A.R.S. §§ 43-123.04 and 43-126(a)(5). 1 These statutes deal with deductions attributable to tax-exempt income. During the two years in question, 1974 and 1975, Continental had certain tax-exempt income consisting of interest from Arizona municipal bonds and interest on obligations of the United States. The major portion of the tax-exempt interest income was from Arizona municipal obligations. Only a minor portion of such income was from United States obligations. Continental also incurred certain interest expenses in connection with its normal banking operations. In accordance with the Department’s interpretation of A.R.S. § 43-126(aX5), Continental excluded from its otherwise allowable deductions the amount of $638,942.84 on its 1974 income tax return, and the amount of $513,717.47 on its 1975 income tax return. It then filed a claim for refund of $27,017.49 for 1974 and $53,940.29 for 1975.

The second statute challenged by Continental is A.R.S. § 43-123.21(EX2). This provision adds tax-exempt income to gross income when computing a net operating loss (NOL) and has the effect of reducing or extinguishing an NOL which is carried forward and used as a deduction in computing future net income. A.R.S. § 43-123.21.

The Department of Revenue raises the following questions on its appeal from the judgment in favor of Continental Bank:

(1) Whether interest expense must be “connected with” tax-exempt interest before the disallowance formula of A.R.S. § 43-126(aX5) can be applied.
(2) If such expense need not be “connected with” tax-exempt interest, whether A.R.S. § 43-126(a)(5) is constitutional.
*8 (3) Whether A.R.S. § 43-123.21, which disallows an otherwise available net operating loss deduction to taxpayers who own tax-exempt securities, is constitutional.

ALLOCATION OF DEDUCTIONS TO TAX-EXEMPT INCOME

The first issue to be discussed is whether a connection must exist between a deduction and exempt income before ■ the deduction is disallowed. There are three statutes involved in this issue. Two of the statutes disallow the interest deduction. A.R.S. § 43-123.03(0) is the general deduction disallowance section and states:

The deductions permitted by subsection A of this section shall not be allowed to the extent that they are connected with the production of income not taxable under this title. Proper apportionment and allocation of such deductions with respect to taxable and nontaxable income shall be determined pursuant to § 43-126, subsection (a), paragraph (5). (emphasis added)

A.R.S. § 43-123.04 is the specific section dealing with interest deductions:

In computing net income there shall be allowed as a deduction all interest paid or accrued within the taxable year on indebtedness of the taxpayer. However, no deduction shall be allowed to the extent that it is connected with income not taxable under this title. The proper apportionment and allocation of the deduction with respect to taxable and nontaxable income shall be determined under rules and regulations prescribed by the tax commission, (emphasis added)

The third section, A.R.S. § 43-126(a)(5), sets forth the formula for determining the amount which is nondeductible:

In computing net income no deduction shall in any case be allowed in respect of:
(5) Any amount otherwise allowable as a deduction which is allocable to one or more classes or [s/c: of] income (whether or not any amount of income of that class or classes is received or accrued) wholly exempt from the taxes imposed by this title. In determining this nondeductible amount, the taxpayer shall divide tax exempt interest as defined in § 43-112, subsection (b), paragraph (10) by gross income as defined in section 43-112 plus tax exempt income as defined in § 43-112, subsection (b), paragraph (10), and multiply that figure by the interest deduction which is otherwise allowed pursuant to § 43-123:04. In addition, the taxpayer shall , add ten per cent of the tax exempt income as defined in § 43-112, subsection (b), paragraph (10) which represents nondeductible administrative expenses related to the production of tax exempt income.

The Department contends that there need not be any direct connection between interest expense incurred and exempt income before the formula in A.R.S. § 43-126(a)(5) is applied; only a temporal connection need exist. In other words, anytime interest expense and tax-exempt income exist during the same tax year, the formula should be applied. Continental contends, however, that the existence of a direct connection between the deduction and exempt income is a prerequisite to applying the formula. We agree with Continental in this two-step construction. The Department’s interpretation ignores the plain language of the statutes involved.

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Bluebook (online)
638 P.2d 228, 131 Ariz. 6, 1981 Ariz. App. LEXIS 576, Counsel Stack Legal Research, https://law.counselstack.com/opinion/continental-bank-v-arizona-department-of-revenue-arizctapp-1981.