DenHerder v. Dept. of Rev.

CourtOregon Tax Court
DecidedSeptember 27, 2023
DocketTC-MD 210393R
StatusUnpublished

This text of DenHerder v. Dept. of Rev. (DenHerder v. Dept. of Rev.) 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
DenHerder v. Dept. of Rev., (Or. Super. Ct. 2023).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Income Tax

MONICA J. DENHERDER ) and CHARLES A. DENHERDER, ) ) Plaintiffs, ) TC-MD 210393R ) v. ) ) DEPARTMENT OF REVENUE, ) State of Oregon, ) ) Defendant. ) DECISION

Plaintiffs appealed Defendant’s Notices of Assessment for the 2016 and 2018 tax years.

A trial was held remotely on July 19, 2022, via Webex. Plaintiff Monica DenHerder

(DenHerder) appeared and testified on behalf of Plaintiffs. Auditor Cecily Gutierrez (Gutierrez)

appeared on behalf of Defendant. Plaintiffs’ Exhibits 1 to 16 and Defendant’s Exhibits A to F

were admitted without objection. The parties stipulated ahead of trial that only the 2016 tax year

remained at issue; specifically, Plaintiffs challenged 29 items from Defendant’s bank deposit

analysis.

I. STATEMENT OF FACTS AND ANALYSIS

The facts of this case primarily concern the source of deposits in Plaintiffs’ bank accounts

and Plaintiffs’ adjusted basis for personal property that was sold. Defendant found an additional

$77,430 of schedule C gross receipts during a bank deposit analysis.1 At trial, DenHerder

asserted that 29 of the deposits Defendant relied on for the adjustment to Plaintiffs’ 2016 income

represented six different types of non-income events: (1) deposits from the sale of personal

1 The amount stated in Defendant’s bank deposit analysis is different than the Notice of Assessment. (Def. Ex E at 1.) The parties did not address this issue at trial, and thus, the court uses the figure in the Notice.

DECISION TC-MD 210393R 1 property and equipment; (2) deposits constituting transfers between bank accounts; (3) deposits

from loans given by family members; (4) dividends from long-term capital gains; (5) a federal

income tax refund; and (6) cash gifts from a family member.

For background, DenHerder testified that she and her family made an abrupt relocation

from Alaska to Oregon in May 2013, necessitated by her family members’ medical issues.

DenHerder explained that because of the speed of the relocation, she did not have a job when

they came to Oregon, and they were living on savings. DenHerder testified that in late 2014 or

early 2015, Plaintiffs began their Oregon business, Hybrid Woodcrafting LLC, specializing in

deck repairs and renovations. Although this business eventually grew, DenHerder testified that

when Plaintiffs’ finances were tight, they periodically sold personal property they no longer

needed in order to pay bills and make ends meet, especially during the off season.

DenHerder also testified that Plaintiffs maintained a few bank accounts for their personal

and business activities. DenHerder explained she used a BECU credit union account for her

personal banking and two Northwest Credit Union accounts—a business checking account and a

business savings account for eventual payment of taxes—for Plaintiffs’ Hybrid Woodcrafting

LLC business. She also made occasional transfers from her minor daughter’s bank account

when in a pinch to cover bills, which she reimbursed with interest. She also explained her

general practice of trying to get checks received for the business’s activities written as payable to

the business and checks related to personal activities and personal property payable to her or her

husband.

A. General Statements of Law

In analyzing Oregon income tax cases, the court starts with several general guidelines.

First, the court is guided by the intent of the legislature to make Oregon’s personal income tax

law identical in effect to the federal Internal Revenue Code (IRC) for the purpose of determining

DECISION TC-MD 210393R 2 taxable income of individuals. ORS 316.007(1).2 Second, in cases before the court, the party

seeking affirmative relief bears the burden of proof and must establish his or her case by a

“preponderance” of the evidence. ORS 305.427. That standard is met by showing that “the facts

asserted are more probably true than false[.]” Cook v. Michael, 214 Or 513, 527, 330 P2d 1026

(1958). “[I]f the evidence is inconclusive or unpersuasive, the taxpayer will have failed to meet

his burden of proof * * *.” Reed v. Dept. of Rev., 310 Or 260, 265, 798 P2d 235 (1990).

B. Schedule C Gross Income Adjustment

Gross income is defined as “all income from whatever source derived, including (but not

limited to) * * * (1) Compensation for services * * *; (2) Gross income derived from business;

(3) Gains derived from dealings in property; * * * (7) Dividends * * *.” IRC § 61(a). A

taxpayer has a duty to keep their financial records to prove their income and deductions. Treas

Reg § 1.6001-1(a). “Where a taxpayer’s books do not clearly reflect income, the Department of

Revenue may demonstrate unreported income ‘by any practicable proof that is available in the

circumstances of the particular situation.’” Danielson v. Dept. of Rev., TC-MD 160282C, 2017

WL 5158730 at *3 (Or Tax M Div, Nov 7, 2017) (quoting Brenner v. Dept. of Rev.,

9 OTR 299, 306 (1983) (citation omitted); cf U.S. v. Doyle, 234 F2d 788, 793 (7th Cir 1956)).

The department may use additional methods, such as a bank deposit analysis, to determine a

taxpayer’s unreported income. Brenner, 9 OTR at 302 n 2. “The reconstruction need only be

reasonable in light of all surrounding facts and circumstances.” Petzoldt v. Comm’r, 92 TC 661,

687 (1989) (citation omitted). “The bank deposits method is a permissible method of

reconstructing income. * * * Bank deposits constitute prima facie evidence of income.”

Ekwenugo v. Comm’r, 102 TCM (CCH) 321, WL 4484788 at *3 (2011) (citations omitted).

2 References to the Oregon Revised Statutes (ORS) are to 2015.

DECISION TC-MD 210393R 3 “[T]he taxpayer must prove that the reconstruction is in error and may do so, in whole or in part,

by proving that a deposit is not taxable.” Id.

1. Item 1: radial arm saw

DenHerder testified the first contested deposit, Item 1, was a radial arm saw she

characterized as personal property that Plaintiffs sold in 2016. She indicated that on August 16,

2014, her husband purchased the saw for $350 from a garage sale, and she supported this

assertion with a check stub from the purchase that indicates “radial arm saw” in the memo line.

(Ptfs’ Ex 5 at 1.) DenHerder testified that her husband bought the saw for use in his woodshop.

She explained that the saw was never used—and never meant—for Plaintiffs’ business because

the saw’s large size and weight made it unsuitable for moving between jobs, and the saw’s

design presented too significant a risk to employee safety. DenHerder testified that the saw was

never included in their tax returns as depreciable property, and the Plaintiffs sold the saw at a

loss to help pay bills. DenHerder provided a copy of a cancelled check dated “8 Jan 2016” from

Kent and Susan Miller for $325 made out to Monica DenHerder as proof of the sale of the saw.

(Ptfs’ Ex 2 at 1; Ex 3 at photo 2.) DenHerder noted the check being made out to her personally,

not to the business, further indicated the saw was not related to the business. (Id.) Defendant did

not offer anything to rebut Plaintiffs’ evidence.

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Related

Commissioner v. Tufts
461 U.S. 300 (Supreme Court, 1983)
Cook v. Michael
330 P.2d 1926 (Oregon Supreme Court, 1958)
Reed v. Department of Revenue
798 P.2d 235 (Oregon Supreme Court, 1990)
Brenner v. Department of Revenue
9 Or. Tax 299 (Oregon Tax Court, 1983)
Scott II v. Dept. of Rev.
23 Or. Tax 58 (Oregon Tax Court, 2018)

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