Frederick Farms, Inc. v. County of Olmsted

801 N.W.2d 167, 2011 Minn. LEXIS 467, 2011 WL 3480990
CourtSupreme Court of Minnesota
DecidedAugust 10, 2011
DocketNo. A10-1089
StatusPublished
Cited by12 cases

This text of 801 N.W.2d 167 (Frederick Farms, Inc. v. County of Olmsted) is published on Counsel Stack Legal Research, covering Supreme Court of Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Frederick Farms, Inc. v. County of Olmsted, 801 N.W.2d 167, 2011 Minn. LEXIS 467, 2011 WL 3480990 (Mich. 2011).

Opinion

OPINION

STRAS, Justice.

In 2008, Olmsted County changed the property tax classification of farmland owned by Frederick Farms, Inc., from agricultural-homestead to agricultural-non-homestead property. The Minnesota Tax Court denied Frederick Farms’ petition to change the classification of the property back to agricultural homestead for taxes payable in 2009 and later. Frederick Farms appealed to this court, arguing that [169]*169it is operating a joint family farm venture with its sole shareholder, James Frederick, and that the County must classify Frederick Farms’ property as agricultural-homestead property because it is used by the joint family farm venture. Because we conclude that a joint family farm venture must own or lease, and not merely use, the property in order for a participant of the joint family farm venture to claim an agricultural-homestead classification, we affirm the decision of the tax court.

I.

The material facts of this case are undisputed. Frederick Farms owns three contiguous parcels of land in Olmsted County totaling 300 acres. The only structures on Frederick Farms’ parcels are grain bins. The sole shareholder of Frederick Farms, James Frederick, personally owns and resides on two parcels totaling 80 acres that are contiguous with the 300 acres of land owned by Frederick Farms. Mr. Frederick farms the entire 380 acres as a single farm, using farm equipment mostly owned by Frederick Farms and hiring day laborers when necessary.

Prior to 2008, Olmsted County classified all of the contiguous parcels owned by Mr. Frederick and by Frederick Farms as agricultural-homestead property for tax purposes. In 2008, the County reclassified the 300 acres owned by Frederick Farms as agricultural-nonhomestead property, which is taxed at a higher rate than agricultural-homestead property. Compare MinmStat. § 273.13, subd. 23(a) (2010) (providing the tax rates for agricultural-homestead property), with Minn.Stat. § 273.13, subd. 23(b) (2010) (providing the tax rates for agricultural property). The 80 acres of land personally owned by Mr. Frederick remain classified as agricultural-homestead property.

Frederick Farms petitioned the Olmsted County District Court for relief, claiming that Olmsted County’s decision to reclassify the 300 acres of property from agricultural-homestead to agricultural-nonhome-stead property was improper. The case was transferred to the Minnesota Tax Court, which denied Frederick Farms’ motion for summary judgment. To facilitate an appeal, and because the material facts of the case were not in dispute, the parties stipulated to entry of judgment in favor of Olmsted County. Following the tax court’s entry of judgment in favor of Olmsted County, Frederick Farms petitioned this court for a writ of certiorari.

We review tax court decisions “to determine whether the tax court lacked subject matter jurisdiction, whether the tax court’s decision is supported by evidence in the record, and whether the tax court made an error of law.” Hohmann v. Comm’r of Revenue, 781 N.W.2d 156, 157 (Minn.2010). In this case, our review is de novo because the facts are undisputed and the only question is whether the tax court correctly applied Minnesota law. See id.

II.

We first address the basis for the tax court’s judgment. The court entered judgment in favor of Olmsted County on the ground that Frederick Farms was ineligible for agricultural-homestead classification on the 300 acres of land it owns because James Frederick had already claimed an agricultural-homestead classification on the 80 acres of property he personally owns. Granting agricultural-homestead status to both would, according to the court, violate Minn.Stat. § 273.124, subd. 14(g) (2010).

The provision relied upon by the tax court, section 273.124, subdivision 14(g), states that “[ajgricultural property of a family farm corporation, [or a] joint family [170]*170farm venture ... shall be classified homestead, to the same extent as other agricultural homestead property” if certain criteria are met. One such criterion is that a shareholder of a family farm corporation who is “actively farming the agricultural property” may not “claim[] another agricultural homestead in Minnesota.” Minn. Stat. § 273.124, subd. 14(g)(4).

It is undisputed that Mr. Frederick, Frederick Farms’ sole shareholder and the person who is actively farming the Frederick Farms property, continues to claim an agricultural-homestead classification on the 80 acres of property he personally owns. As the tax court correctly recognized, subdivision 14(g) prohibits Frederick Farms from claiming an agricultural-homestead classification on its 300 acres so long as Mr. Frederick claims an agricultural-homestead classification on the 80 acres he personally owns.

Although technically correct based on its view of the relevant facts and arguments of the parties, the tax court’s analysis was incomplete. Frederick Farms does not claim a separate agricultural-homestead classification on the 300 acres it owns, in addition to the agricultural-homestead classification Mr. Frederick already receives on his 80 acres. Rather, Frederick Farms asserts that Frederick Farms and Mr. Frederick — not as separate entities, but together as one joint family farm venture — are entitled to one agricultural-homestead classification on the entire 380 acres. Subdivision 14(g) — which prohibits the actively farming shareholder and the family farm corporation from both claiming separate agricultural-homestead classifications — does not address this question. Therefore, although the tax court’s analysis is consistent with the language of subdivision 14(g), we must turn to other statutory provisions in order to address the issue raised by Frederick Farms.

III.

We thus turn to the question of whether Frederick Farms may claim an agricultural-homestead classification for its 300 acres as part of a 380-acre joint family farm venture. According to Frederick Farms, the 300 acres it owns and the 80 acres personally owned by Mr. Frederick are contiguous parcels that constitute a single farm, all of which the County should classify as agricultural-homestead property. We disagree.

A.

A “joint family farm venture” is “a cooperative agreement among two or more farm enterprises authorized to operate a family farm under section 500.24.” Minn. Stat. § 273.124, subd. 8(a) (2010). We will assume without deciding that Mr. Frederick and Frederick Farms have formed a valid joint family farm venture under Minn.Stat. § 273.124, subd. 8(a).

Frederick Farms’ claim for agricultural-homestead classification for the 300 acres it owns still fails, however, because the joint family farm venture, to the extent it exists, does not own or lease the land in question. Subdivision 8(a) of MinmStat. § 273.124 provides:

Each family farm corporation; each joint family farm venture; and each limited liability company or partnership which operates a family farm; is entitled to class lb under section 273.13, subdivision 22, paragraph (b), or class 2a assessment for one homestead occupied by a shareholder, member, or partner thereof who is residing on the land, and actively engaged in farming of the land owned by the family farm corporation, joint family farm venture, limited liability company, or partnership.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
801 N.W.2d 167, 2011 Minn. LEXIS 467, 2011 WL 3480990, Counsel Stack Legal Research, https://law.counselstack.com/opinion/frederick-farms-inc-v-county-of-olmsted-minn-2011.