Fairfax County v. DataComp Corp.

36 Va. Cir. 60, 1995 Va. Cir. LEXIS 1257
CourtFairfax County Circuit Court
DecidedFebruary 22, 1995
DocketCase No. (Law) 128829
StatusPublished

This text of 36 Va. Cir. 60 (Fairfax County v. DataComp Corp.) is published on Counsel Stack Legal Research, covering Fairfax County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fairfax County v. DataComp Corp., 36 Va. Cir. 60, 1995 Va. Cir. LEXIS 1257 (Va. Super. Ct. 1995).

Opinion

By Judge Stanley P. Klein

Plaintiff, County of Fairfax, brought this action pursuant to Va. Code § 58.1-3953 demanding payment of taxes, penalties, and interest charges allegedly owed by the Defendant DataComp Corporation on delinquent Business, Professional, and Occupational License (BPOL) taxes for tax years 1989 through 1993. Plaintiff claimed that as of December 15,1994, the Defendant owed $7,103.16 in taxes, late filing penalties, late payment penalties, and interest assessed under a Wholesale Merchant License pursuant to Fairfax County Code § 4-7-26 and $1,333.26 in taxes, late filing penalties, late payment penalties and interest assessed under a Repair/Service License pursuant to Fairfax County Code § 4-7-23.

Fairfax County Code § 4-7-26 imposes an annual license tax on the privilege of wholesale merchant occupations at a rate of four cents for each $100.00 of gross purchases for the year. Fairfax County Code § 4-7-23 imposes an annual license tax on the privilege of repair service occupations at a rate of eighteen cents for each $100.00 of gross receipts for the year.

Defendant filed an Answer and Grounds of Defense along with an Application to Correct Erroneous Assessment and Refund of Taxes, claiming [61]*61that it is not liable for the claimed BPOL taxes, because, as a manufacturer, it qualifies for the exemption from license taxes provided under Va. Code § 58.1-3703(B)(4).

The Court initially took this case under advisement to determine (1) whether the Defendant qualifies as a manufacturer for purposes of Va. Code § 58.1-3703(B)(4), and (2) if so, whether the Defendant is exempt from the BPOL taxes assessed under both the Wholesale Merchant license and the Repair/Service license. Based upon what the Court determined was an honest misunderstanding between counsel as to the scope of the parties’ pre-trial stipulations, it invited the parties to put on further evidence, post-trial, on the additional issue of whether the defendant was selling its products “at wholesale” for the purposes of Va. Code § 58.1-3703(B)(4) during the tax years in question. The Court has fully considered the evidence and arguments set forth at trial and at the post-trial hearing as well as those arguments set forth in the parties’ trial briefs and post-trial memoranda.

I. Factual Background

DataComp is in the business of producing and selling personal computers, file servers, and computer parts. In 1988, DataComp opened a “manufacturing plant” in Fairfax County to fulfill its obligation under a contract with the Department of Labor. Since then, the Defendant has continued to contract with and provide computer networks to various government agencies, labor unions, law firms, and “re-sellers.” In producing its computers, DataComp acquires various component parts such as motherboards, power switches, cabling, and brackets from original equipment manufacturers (OEMs). These individual parts are tested to ensure quality and compatibility with FCC standards. DataComp technicians then assemble and integrate these parts into a final product in accordance with contract specifications. This process includes the soldering, taping, and connecting of these materials by trained employees.

DataComp has principally relied on the defense that it qualifies for the exemption under Virginia Code § 58.1-3703(B)(4), which provides that no county shall levy any license tax “[o]n a manufacturer for the privilege of manufacturing and selling goods, wares, and merchandise at wholesale at the place of manufacture.” It is the County’s position that DataComp’s business activity does not constitute manufacturing for purposes of tins exemption but consists of mere assembly of ready-made parts. Addition[62]*62ally, the County has argued that DataComp is not selling computers “at wholesale” as required by the statute.

The County also argued at trial that DataComp should be barred from contesting the tax assessments for 1989 through 1990 by Va. Code § 58.1-3984 which provides, in part, that:

[a]ny person assessed with local taxes aggrieved by any such assessment, may, unless otherwise specially provided by law, within three years from the last day of the tax year for which any such assessment is made, or within one year from the date of the assessment, whichever is later, apply for relief to the circuit court of the county or city wherein such assessment was made.

The Court disagrees. Pursuant to Va. Code § 58.1-3955, the Court has the power to order exoneration of any taxes that have been erroneously charged, for which collection is sought pursuant to § 58.1-3953. In such cases, the Court is limited only by the five-year statute of limitations imposed upon the collection of local taxes as set forth in § 58.1-3940.

H. Burden of Proof

When a taxpayer petitions the Court to correct an erroneous assessment, the assessment is presumed to be correct and the taxpayer bears the burden of proving that it is “otherwise invalid or illegal.” Va. Code § 58.1-3984; Fairfax County v. Leasco, 221 Va. 158, 160 (1980); Norfolk & Western Ry. Co. v. Commonwealth, 211 Va. 692 (1971); Shaia v. City of Richmond, 207 Va. 885, 892, 893, n. 7 (1967) ([E]ven if the assessor is unable to come forward with evidence to prove the correctness of the assessment, this does not impeach it since the taxpayer has the burden of proving the assessment erroneous.) Likewise, in claiming an exemption from taxation, the taxpayer bears the burden of proving its qualification. Board of Supervisors of Fairfax County v. Group Health Association, 243 Va. 296, 299 (1992); County of Henrico v. Management Recruiters, 221 Va. 1004 (1981). The exemption statute is to be construed strictly against the taxpayer and when susceptible of two constructions, one granting an exemption and the other not granting it, the Court should adopt a construction denying the exemption. Solite Corp, v. King George Co., 220 Va. 661, 662 (1980) citing Commonwealth v. Community Motor Bus., 214 Va. 155, 157 (1973); See also Webster v. Dept. of Taxation, 219 Va. 81, 84 (1978) (Construction of a statute by a state official charged with its administration, although not binding on the Court, is entitled to great weight.) Thus, [63]*63the burden falls on defendant DataComp to prove, by a preponderance of the evidence, that it qualifies as a manufacturer under Va. Code § 58.1-3703(B)(4), and that the taxes assessed by the County were therefore erroneous.

III. Is DataComp a Manufacturer?

Determining whether DataComp qualifies as a “manufacturer” for purposes of Va. Code § 58.1-3703(B)(4) involves a two part analysis. The Court must first consider whether some of DataComp’s business activities constitute “manufacturing” as defined by the Virginia Supreme Court, and second, whether these activities, if deemed to be manufacturing, meet the test of substantiality. County of Chesterfield v. BBC Brown Boveri, 238 Va. 64 (1989).

In characterizing DataComp’s activities, the definition of manufacturing should be liberally construed, consistent with the public policy of Virginia to encourage manufacturing in the Commonwealth. County of Chesterfield, 238 Va. at 69, citing Prentice v. City of Richmond, 197 Va. 724 (1956).

In Prentice,

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Cite This Page — Counsel Stack

Bluebook (online)
36 Va. Cir. 60, 1995 Va. Cir. LEXIS 1257, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fairfax-county-v-datacomp-corp-vaccfairfax-1995.