Finley v. Department of Revenue

CourtOregon Tax Court
DecidedNovember 15, 2012
DocketTC-MD 111135C
StatusUnpublished

This text of Finley v. Department of Revenue (Finley 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
Finley v. Department of Revenue, (Or. Super. Ct. 2012).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Income Tax

RYAN FINLEY, ) ) Plaintiff, ) TC-MD 111135C ) v. ) ) DEPARTMENT OF REVENUE, ) State of Oregon, ) ) Defendant. ) DECISION

This matter is before the court on cross-motions for summary judgment. The filing of the

parties‟ motions and supporting memoranda was completed August 16, 2012, and oral argument

was held in Salem on September 17, 2012. Plaintiff was represented by Larry J. Brant and John

Rothermich, both of whom are attorneys at the law firm of Garvey Schubert Barer, Portland,

Oregon. Defendant was represented by Douglas M. Adair and James C. Wallace, Senior

Assistant Attorneys General, Oregon Department of Justice.

Plaintiff appeals Defendant‟s imposition of interest on underpayment of estimated tax for

the 2009 tax year, asserting that “Defendant should have used to the Prior Year Safe Harbor

Method to calculate the interest assessment for underpayment of Oregon estimated taxes.” (Ptf‟s

Compl at 3, ¶ IX.) Plaintiff‟s 2008 Oregon return was not timely filed and Defendant relied on

its administrative rule to deny Plaintiff the benefits of the statutory safe harbor provision found

in ORS 316.587(8)(b).1 (Def‟s Ans at 1-2; Def‟s Cross Mot for Summ J at 2.) In so doing

Defendant asserted an assessment of interest in the amount of $298,342.98, later reduced to

$224,863. (Ptf‟s Compl at 2-3, ¶¶ V, VIII; Def‟s Cross Mot for Summ J at 2.) Plaintiff contends

that the statutory safe harbor provision should apply and that the amount of interest should be

1 All references to the Oregon Revised Statutes (ORS) are to 2007.

DECISION TC-MD 111135C 1 only $42,268. (Ptf‟s Compl at 3, ¶ IX; Ptf‟s Mem Supp Summ J at 17.) Plaintiff argues that

Defendant‟s rule requiring the timely filing of the prior year‟s return is invalid because it

conflicts with the plain language of ORS 316.587(8) and “creates a disparity between the

application of the Prior Year Safe Harbor and its federal counterpart,” which, Plaintiff asserts,

contravenes the “clear legislative intent of the statute.” (Ptf‟s Mem Supp Summ J at 2.)

I. STATEMENT OF FACTS

Plaintiff ‟s memorandum in support of its request for summary judgment provides the

following facts, which Defendant does not dispute. (Def‟s Cross-Mot for Summ J at 1: “The

facts are not in dispute.”) Plaintiff was an Oregon resident in 2008 and 2009. (Ptf‟s Mem Supp

Summ J at 2.) Plaintiff filed his 2008 and 2009 Oregon individual tax returns on a calendar year

basis. (Id. at 2-3.) Both returns were based on taxable years of 12 months. (Id. at 3.)

Plaintiff filed his 2008 Oregon return on February 12, 2010, reporting a tax liability of

$2,153,260. (Id.) Eight months later, on or about October 15, 2010, Plaintiff filed his 2009

Oregon return reporting a tax liability of $9,928,537. (Id.) Plaintiff made Oregon estimated

income tax payments for 2009 totaling $8,771,633.2 (Id.)

On November 12, 2010, Defendant issued a Notice of Tax Assessment that included

interest on underpayment of estimated tax in the amount of $298,342.98. (Aff of Robert P.

Wiest, Ex 1 at 1.) Plaintiff, through his accountant Robert P. Wiest, CPA, sent two letters to

Defendant in February and March 2011 disputing the interest assessment. (Id. at 2, ¶ 5.) The

second of those two letters asserted that the imposition of interest for underpayment of estimated

tax should be further reduced (from the amount asserted in the first letter from Wiest to

2 It appears those payments were made as follows: $550,000 paid June 15, 2009, $417,974 paid January 15, 2010, $7,200,000 paid April 15, 2010, plus a payment of $603,659 applied to Plaintiff‟s 2009 tax liability based on an adjusted overpayment Plaintiff made on his 2008 tax liability. (See Aff of Robert P. Wiest at 1, Ex 1 at 2.)

DECISION TC-MD 111135C 2 Defendant) pursuant to ORS 316.587(8) because Plaintiff‟s estimated tax obligation for 2009

should have been determined under the safe harbor provisions of subsection (8)(b) of ORS

316.587. (Id.)

On July 14, 2011, Defendant issued a Notice of Abatement reducing the assessment of

interest from $298,342.98 to $224,863. (Id., Ex 2 at 1.) According to Defendant‟s abatement

notice, the reduction in the disputed interest (on underpayment of estimated tax) was due to an

adjustment made to reflect the use of the 2008 tax rates. (Id., Ex 2 at 3.) Defendant declined to

calculate the interest under the “safe harbor” method found in ORS 316.587(8), as requested by

Plaintiff. (Id.) Defendant explained in that notice that “the prior-year return must have been

filed timely, including extensions, and cover 12 months. The facts in your case do not qualify

you for this method since your 2008 tax return was not filed until 2/12/10 which is after the

extension period had expired. (ORS 316.587).” (Id.)

II. ISSUE

The issue in this case is whether, for purposes of computing interest on underpayment of

estimated taxes under ORS 316.587(1), a taxpayer can be required to timely file the prior year‟s

return in order to rely on the statutory safe harbor provision in subsection (8)(b) of ORS 316.587

when calculating the amount of estimated taxes required to be paid in the current year.

The case is not about whether Plaintiff paid any estimated taxes in 2009, or whether his

2008 or 2009 Oregon personal income tax returns were timely filed. The case really comes

down to whether the provision in the department‟s administrative rule (OAR 150-316.587 (8)-

(A) (3)(a)(B)) requiring that a taxpayer timely file his tax return for the prior year in order to rely

on the prior year‟s tax for purposes of determining the amount of estimated taxes paid in the

///

DECISION TC-MD 111135C 3 current year (safe harbor) is consistent with the statute (ORS 316.587) and the intent of the

legislature, or whether the rule is invalid, as Plaintiff asserts.

III. ANALYSIS

A. Introduction and overview

1. Statutory framework for declarations and payments of estimated tax

Plaintiff was required by ORS 316.563(1), ORS 316.577, and ORS 316.579 to declare

and pay estimated taxes in 2009 on income not subject to withholding. A declaration of

estimated tax must be filed on or before April 15 of the current taxable year, which in this case

was April 15, 2009.

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