Donna Porcaro v. Director, Division of Taxation

CourtNew Jersey Tax Court
DecidedJune 3, 2024
Docket012296-2020
StatusPublished

This text of Donna Porcaro v. Director, Division of Taxation (Donna Porcaro v. Director, Division of Taxation) is published on Counsel Stack Legal Research, covering New Jersey Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Donna Porcaro v. Director, Division of Taxation, (N.J. Super. Ct. 2024).

Opinion

NOT FOR PUBLICATION WITHOUT APPROVAL OF THE TAX COURT COMMITTEE ON OPINIONS

________________________________________ DONNA PORCARO, TAX COURT OF NEW JERSEY DOCKET NO. 012296-2020

Plaintiff Approved for Publication v. In the New Jersey Tax Court Reports DIRECTOR, DIVISION OF TAXATION,

Defendant.

Decided: May 31, 2024

Donna Porcaro, a self-represented party.

Linzhi Wang, for defendant (Matthew J. Platkin, Attorney General of New Jersey, attorney).

BEDRIN MURRAY, J.T.C.

I. Introduction

This is the court’s opinion following a plenary hearing conducted in the

above-captioned matter. Plaintiff, Donna Porcaro (“plaintiff”), challenges

defendant, Director, Division of Taxation’s (“defendant”) denial of her claim for a

refund of income tax withheld from wages reported on her 2016 New Jersey Gross

Income Tax return. Defendant contends that plaintiff’s protest of the refund denial

notice was untimely and accordingly, filed a motion for summary judgment seeking

dismissal of the complaint for lack of subject matter jurisdiction, under R. 4:6-2(a).

1 In denying defendant’s motion for summary judgment, the court concluded

that a plenary hearing was needed to determine if plaintiff would be able to overcome

the presumption of receipt that attaches to defendant’s December 21, 2017 refund

denial notice (“final determination letter”), under N.J.S.A. 54:50-6(a). Defendant’s

December 21, 2017 final determination letter contains the taxpayer appeal

instructions and triggers the countdown to file a protest or an appeal, under N.J.S.A.

54:49-18.

Plaintiff maintains she did not receive the final determination letter, despite

having received three prior communications from defendant with respect to her 2016

New Jersey Gross Income Tax (“GIT”) return, mailed to the same address. Further,

plaintiff contends that she first became aware of the issuance of the final

determination letter when she received a copy of it from an unnamed Division of

Taxation employee more than two years later. Plaintiff admits that, as a result, she

submitted a protest letter well past the ninety-day filing deadline.

Defendant contends the final determination letter was properly addressed and

mailed to plaintiff’s residence, and a presumption of its receipt attaches under

N.J.S.A. 54:50-6(a).

For the reasons set forth below, the court concludes that defendant has

established a presumption of receipt attaches to the December 21, 2017 final

2 determination letter. As such, the court concludes that plaintiff’s protest filed more

than two years late is untimely, requiring dismissal of the complaint.

II. Preliminary Findings of Fact and Procedural History

On November 5, 2020, plaintiff filed a complaint with the Tax Court

challenging defendant’s final determination letter.

Plaintiff was placed on a thirty-day administrative leave after her involvement

in a shooting incident that took place on December 14, 2015, while on duty as a

police officer. After the conclusion of her administrative leave on or about January

12, 2016, plaintiff remained out of work due to injury or illness associated with the

incident, until her retirement on or about November 1, 2016. She continued to

receive her full salary during this period of time.

In her complaint, plaintiff contends the wages she received while out of work

were erroneously treated as taxable income by her employer, and income taxes

withheld from those payments.

On or about February 3, 2017, after plaintiff filed her 2016 GIT return, the

parties engaged in a series of written communications regarding this issue. Plaintiff

requested defendant refund the income tax withheld.

On April 3, 2017, defendant sent plaintiff a letter requesting that she submit

copies of her W-2 and/or 1099 statement(s) within thirty days. Plaintiff timely

replied.

3 On April 21, 2017, defendant responded, advising that in order to obtain a

refund of the income taxes withheld, plaintiff would need to supply proof that her

employer was reimbursed for part or all of her wages through a workers’

compensation program or other such plan. Plaintiff provided documents

demonstrating that her employer was reimbursed for part of the wages she was paid

while out of work. In all, three wage reimbursements had been made to plaintiff’s

employer totaling approximately $16,000.

By letter dated December 13, 2017, defendant acknowledged receipt of

plaintiff’s documentation, and notified her that her 2016 taxable income had been

adjusted accordingly. Plaintiff received a refund in the amount of $6,005. The letter

advised that she would be receiving an additional refund by paper check. In addition,

the letter instructed plaintiff to supply defendant with proof, if any, of further

reimbursements to her employer.

Plaintiff responded to defendant’s December 13, 2017 letter on the same day,

however, she submitted duplicate information rather than new information that

might further reduce her taxable income. As a result, on December 21, 2017,

defendant issued its fourth and final letter to plaintiff advising that no further

reduction of her taxable wages would be permitted, and that this determination

would be final unless she submitted a written protest within ninety days. Thus,

plaintiff’s protest was due on March 21, 2018.

4 Plaintiff did not file a protest within the ninety-day appeal period. She

contends she did not receive the December 21, 2017 final determination letter,

although it was mailed to the same address as the three prior letters. Plaintiff noted

she would have timely responded to the letter in the same manner she responded to

the three prior notices.

No other written communications were exchanged between the parties for

more than a two-year period. Instead, plaintiff asserts she engaged in a series of

telephone calls with defendant’s representatives, where she received differing

answers as to the time within which she had to pursue her claim. Further, plaintiff

claims she repeatedly asked defendant’s representatives for copies of all documents

in her file pertaining to her refund request, and that she finally received copies of all

four letters in one packet, sometime between March and May 2020. She could not

identify the party who sent her the letters. Plaintiff contends this was the first time

she saw the final determination letter with appeal rights.

On June 2, 2020, plaintiff faxed defendant a cover letter with sixteen pages of

documentation attached in support of her refund claim.

By letter dated October 21, 2020, defendant informed plaintiff that her June

2, 2020 protest was filed more than twenty-six months out of time. In addition,

plaintiff was advised that if she disagreed with defendant’s determination of

5 untimeliness, she could file a complaint with the Tax Court within ninety days of the

date of the notice.

As previously noted, plaintiff filed a complaint with the Tax Court on

November 5, 2020. Thereafter, plaintiff provided defendant with some discovery,

including copies of the four letters she asserts she obtained between March 2020 and

May 2020 from defendant.

Defendant then filed a motion for summary judgment seeking dismissal of

plaintiff’s complaint for untimeliness. In support of its motion, defendant offered

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Donna Porcaro v. Director, Division of Taxation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/donna-porcaro-v-director-division-of-taxation-njtaxct-2024.