Indiana Department of State Revenue v. Farm Credit Services of Mid-America

734 N.E.2d 551, 2000 Ind. LEXIS 712, 2000 WL 1247239
CourtIndiana Supreme Court
DecidedSeptember 1, 2000
Docket49S10-9908-TA-453
StatusPublished
Cited by4 cases

This text of 734 N.E.2d 551 (Indiana Department of State Revenue v. Farm Credit Services of Mid-America) is published on Counsel Stack Legal Research, covering Indiana Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Indiana Department of State Revenue v. Farm Credit Services of Mid-America, 734 N.E.2d 551, 2000 Ind. LEXIS 712, 2000 WL 1247239 (Ind. 2000).

Opinions

ON PETITION FOR INTERLOCUTORY APPEAL

SHEPARD, Chief Justice.

Farm Credit Services of Mid-America (Mid-America), an Agricultural Credit Association, claims it is exempt from Indiana’s Financial Institutions Tax under constitutional principles of intergovernmental tax immunity. We conclude it is only partially exempt.

Facts and Procedural History

Mid-America is part of the Farm Credit System, a nation-wide network of cooperative, borrower-owned banks and lending institutions that were established to provide affordable credit to farmers and ranchers. 12 U.S.C.A. § 2001 (West 1989).1

The system includes twelve Farm Credit Banks (FCBs), located in each of twelve districts. Through local associations, these banks provide real estate loans secured by mortgages. The local associations include Federal Land Bank Associa[553]*553tions (FLBAs), which provide long-term loans, and Production Credit Associations (PCAs), which provide short-term and intermediate loans.

Congress created the Farm Credit System in 1916 and has reformed it several times during the intervening decades. In the early 1980s, the system began to falter under unfavorable economic conditions that threatened the stability of its lending institutions. Congress responded by enacting the Agricultural Credit Act of 1987. The Act authorized voluntary mergers between PCAs and FLBAs in an effort to streamline the structure of the lending bodies. The institution resulting from such a merger is called an Agricultural Credit Association (ACA).

Mid-America was created in 1989 through the merger of two PCAs and two FLBAs. This case arose in March 1997, when Mid-America filed an amended tax return with the Indiana Department of Revenue requesting a refund of the Financial Institutions Tax2 it had paid for the tax years 1993 and 1994. Mid-America asserted that as a federal instrumentality it was immune from state taxation. The Department denied Mid-America’s claim. Mid-America appealed to the Indiana Tax Court, where it prevailed on summary judgment. Farm Credit Serv. of Mid-America v. Department of State Revenue, 705 N.E.2d 1089 (Ind. Tax Ct. 1999).3

Early Tax Immunity Doctrine

The doctrine of intergovernmental tax immunity derives from M’Culloch v. Maryland, 17 U.S. (4 Wheat.) 316, 4 L.Ed. 579 (1819), the landmark case holding that the State of Maryland could not impose a tax on the Bank of the United States. Chief Justice Marshall’s opinion for the Court relied both on the discriminatory nature of the tax and on general principles of federal supremacy. Specifically, Marshall determined that, because the Bank was a “federal instrument” used to carry out the government’s powers, state taxation would unconstitutionally interfere with the exercise of these powers. Id. at 425-37. Marshall explained that the individual states:

have no power, by taxation or otherwise, to retard, impede, burden, or in any manner control the operations of the constitutional laws enacted by congress to carry into execution the powers vested in the general government.

Id. at 436.

This principle was applied broadly for many years thereafter to bar taxation by one sovereign on another, or even on the employees of another. Davis v. Michigan Dep’t of Treasury, 489 U.S. 803, 109 S.Ct. 1500, 103 L.Ed.2d 891 (1989); see also, e.g., Collector v. Day, 78 U.S. (11 Wall.) 113, 20 L.Ed. 122 (1870) (invalidating federal income tax on salary of state judge); Dobbins v. Comm’rs of Erie County, 41 U.S. (16 Pet.) 435, 10 L.Ed. 1022 (1842) (invalidating state tax on a federal officer). In the late 1930s, however, the Court began to narrow its view of tax immunity. In Graves v. New York ex rel. O’Keefe, 306 U.S. 466, 59 S.Ct. 595, 83 L.Ed. 927 (1939), the Court overruled the Dobbins-Day line of cases and held that intergovernmental tax immunity bars only those taxes imposed directly on one sovereign by another, or that discriminate against the sovereign to which they apply. Id. at 481-87. In restraining the scope of tax immunity, the Court explained:

[554]*554[T]he implied immunity of one government and its agencies from taxation by the other should, as a principle of constitutional construction, be narrowly restricted. For the expansion of the immunity of the one government correspondingly curtails the sovereign power of the other to tax, and where that immunity is invoked by the private citizen it tends to operate for his benefit at the expense of the taxing government and without corresponding benefit to the government in whose name the immunity is claimed.

Id. at 483.

Over the intervening years, the doctrine of intergovernmental tax immunity has become, in the Court’s words, “a ‘much litigated and often confused field,’ one that has been marked from the beginning by inconsistent decisions and excessively delicate distinctions.” United States v. New Mexico, 455 U.S. 720, 730, 102 S.Ct. 1373, 71 L.Ed.2d 580 (1982) (internal citations omitted).

Here, both parties agree that ACAs are “federal instrumentalities”, but disagree about the tax implications of this status.

Both parties urge distinct views of tax immunity. Mid-America argues that federal instrumentalities are immune from state taxation unless Congress expressly waives such immunity, while the Department argues that federal instrumentalities are subject to state taxation unless Congress expressly exempts the instrumentality from taxation.

The Department’s View

In asserting that ACAs are subject to state taxation absent a congressional statement otherwise, the Department directs us to Arkansas v. Farm Credit Serv. of Cent. Arkansas, 520 U.S. 821, 117 S.Ct. 1776, 138 L.Ed.2d 34 (1997). In that case, four PCAs brought suit in U.S. District Court claiming an exemption from Arkansas sales and income taxes. The District Court granted the PCAs’ motion for summary judgment, and the Court of Appeals for the Eighth Circuit affirmed. Farm Credit Serv. of Cent. Arkansas v. Arkansas, 76 F.3d 961 (8th Cir.1996).

The Supreme Court reversed on jurisdictional grounds, holding that, under the Tax Injunction Act, 28 U.S.C. § 1341, PCAs cannot sue in federal court for an injunction against state taxation unless the United States is a co-plaintiff. Arkansas v. Farm Credit, 520 U.S. at 831-32, 117 S.Ct. 1776. In so holding, the Court considered the long-standing power of the federal government to sue to protect itself or its instrumentalities from state taxation. The Court ultimately determined that, although PCAs are congressionally designated federal instrumentalities, this designation “does not in and of itself entitle an entity to the same exemption the United States has under the Tax Injunction Act.” Id. at 832,117 S.Ct. 1776.4

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734 N.E.2d 551, 2000 Ind. LEXIS 712, 2000 WL 1247239, Counsel Stack Legal Research, https://law.counselstack.com/opinion/indiana-department-of-state-revenue-v-farm-credit-services-of-mid-america-ind-2000.