International Rivercenter Lessee, L.L.C. v. Kimberly L. Robinson, in Her Capacity as Secretary of the Department of Revenue, State of Louisiana

CourtLouisiana Court of Appeal
DecidedDecember 28, 2022
Docket2022-CA-0428
StatusPublished

This text of International Rivercenter Lessee, L.L.C. v. Kimberly L. Robinson, in Her Capacity as Secretary of the Department of Revenue, State of Louisiana (International Rivercenter Lessee, L.L.C. v. Kimberly L. Robinson, in Her Capacity as Secretary of the Department of Revenue, State of Louisiana) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
International Rivercenter Lessee, L.L.C. v. Kimberly L. Robinson, in Her Capacity as Secretary of the Department of Revenue, State of Louisiana, (La. Ct. App. 2022).

Opinion

INTERNATIONAL * NO. 2022-CA-0428 RIVERCENTER LESSEE, L.L.C. * COURT OF APPEAL VERSUS * FOURTH CIRCUIT KIMBERLY L. ROBINSON, IN * HER CAPACITY AS STATE OF LOUISIANA SECRETARY OF THE ******* DEPARTMENT OF REVENUE, STATE OF LOUISIANA

APPEAL FROM BOARD OF TAX APPEALS NO. 12329D Honorable Judge Tony Graphia (ret.) ****** Judge Dale N. Atkins ****** (Court composed of Judge Edwin A. Lombard, Judge Daniel L. Dysart, Judge Dale N. Atkins)

Jesse R. Adams, III Camanda J. Fergus JONES WALKER LLP 201 St. Charles Avenue, Suite 5100 New Orleans, LA 70170-5100

COUNSEL FOR PLAINTIFF/APPELLANT, International Rivercenter Lessee, LLC

Aaron Long Antonio C. Ferachi Christopher Brault LOUISIANA DEPARTMENT OF REVENUE P.O. Box 4064 617 N. Third Street (70802) Baton Rouge, Louisiana 70821-4064

COUNSEL FOR DEFENDANT/APPELLEE, Louisiana Department of Revenue

AFFIRMED December 28, 2022 DNA EAL DLD This is a tax assessment dispute. Appellant, International Rivercenter

Lessee, LLC (“International Rivercenter”), seeks review of the January 13, 2022

judgment of the Louisiana Board of Tax Appeals (“Board”), which sustained the

Exceptions of Peremption and Lack of Subject Matter Jurisdiction filed by

Appellee, the Louisiana Department of Revenue (“Department”). For the

following reasons, we affirm.

FACTUAL BACKGROUND AND PROCEDURAL HISTORY

INTERNATIONAL RIVERCENTER’S FEBRUARY 26, 2020 PETITION TO RECOVER TAXES PAID UNDER PROTEST

On February 26, 2020, International Rivercenter filed with the Board a

Petition to Recover Taxes Paid Under Protest (“Petition”). Therein, International

Rivercenter explained that it operated the Hilton Riverside Hotel in New Orleans,

Louisiana, for the tax period running from January 1, 2010, through June 2013

(“relevant tax period”).1 In the Petition, International Rivercenter stated that the

1 Each account is further discussed in the Opinion, but we point out that the

two relevant tax accounts spanned different time periods. The New Orleans Exhibition Hall Tax Account period ran from January 1, 2010, through June 30, 2013; and the New Orleans Hotel/Motel Tax Account period ran from January 1, 2011, through June 1, 2013.

1 Department issued Notices of Assessment (“Notices”) to International Rivercenter

under New Orleans Hotel/Motel Tax account #0207332-001-450 (“Hotel/Motel

Account”) and under New Orleans Exhibition Hall Tax Account #0207332-001-

490 (“Exhibition Hall Account”) for taxes owed for the relevant tax period;2 but

International Rivercenter alleged that it did not receive these Notices and was not

aware of the assessments until 2016 upon receipt of a demand for payment

(“demand”). International Rivercenter contended that it submitted a protest to the

demand on April 14, 2016, wherein International Rivercenter “outlin[ed] the

deficiencies in the Notices and also disput[ed] that [it] owed any additional taxes as

alleged in the Notices for the Tax Period[].” International Rivercenter asserted in

the Petition that it did not receive a response from the Department regarding the

protest.3 International Rivercenter also contended that on October 25, 2019, the

Department issued a Statement of Account, wherein “the Department contend[ed]

that [International Rivercenter] continue[d] to owe delinquent Sales Tax and

interest for the [relevant tax periods].”4 Further, International Rivercenter

explained that it ultimately paid under protest the taxes allegedly due for the

relevant tax periods under the Hotel/Motel Account and under the Exhibition Hall

Account on January 29, 2020.

2 Attached to the Department’s Exceptions of Peremption and Lack of Subject Matter Jurisdiction, which are discussed more fully throughout this Opinion, are thirty and sixty-day Notices that the Department alleged that it issued to International Rivercenter for both the Hotel/Motel Account and the Exhibition Hall Account. The thirty and sixty-day Notices are dated October 30, 2014, and December 30, 2014, respectively. 3 The record before this Court lacks evidence of the alleged 2016 demand

and protest. 4 The appellate record also lacks evidence of the alleged October 25, 2019

Statement of Account.

2 Additionally, in the Petition, International Rivercenter explained:

Petitioner occasionally offered complimentary rooms in the following instances, where no charge was made by Petitioner and no payment was received from the guests: (1) rooms provided to employees for work or personal travel, (2) rooms provided as part of a convention (e.g., for every 50 rooms booked, one room is provided on a complimentary basis), (3) rooms provided to potential clients during site visits, or to familiarize travel agents or tour operators with the hotel, (4) rooms provided to guests because of customer service issues, or (5) rooms provided on a complimentary basis as a donation to charitable organizations or for fundraising events.

Regarding these complimentary rooms, International Rivercenter stated that

“[u]pon information and belief, the Protest Amount relates to the Department’s

position that hotel rooms provided by [International Rivercenter] on a

complimentary basis are subject to Sales Tax at their purported full retail value.”

However, International Rivercenter disputed this and argued that “[i]n order for

Sales Tax to be imposed, there must be an amount ‘paid or charged’ for the

service[,]” which does not apply to rooms allocated on a complimentary basis.

THE DEPARTMENT’S JUNE 22, 2021 EXCEPTIONS OF PEREMPTION AND LACK OF SUBJECT MATTER JURISDICTION

In response to International Rivercenter’s Petition, the Department filed on

June 22, 2021, Exceptions of Peremption and Lack of Subject Matter Jurisdiction

(collectively “Exceptions”). Therein, the Department urged its Exception of

Peremption on the basis that “[p]ursuant to La. R.S. 47:1565, a taxpayer has sixty

(60) days from the date of mailing of the [Notices] and Notice of Right to Appeal

to the Louisiana Board of Tax Appeals to either pay the amount of the assessment

or to appeal to the Louisiana Board of Tax Appeals for a redetermination of the

assessment.” The Department contended that it issued the sixty-day Notice to

International Rivercenter on December 30, 2014, such that International

Rivercenter’s February 26, 2020 Petition was well beyond the sixty day deadline

3 provided in La. R.S. 47:1565. Thus, The Department contended that International

Rivercenter’s failure to timely take action rendered the Notice final and that

preemption prevented International Rivercenter the from challenging the

assessments.

In urging its Exception of Lack of Subject Matter Jurisdiction, the

Department argued that because International Rivercenter failed to timely act, the

Board lacked subject matter jurisdiction to review the Department’s tax

INTERNATIONAL RIVERCENTER’S SEPTEMBER 7, 2021 OPPOSITION TO THE EXCEPTIONS

In a September 7, 2021 opposition to the Department’s Exceptions,

International Rivercenter argued that the assessments failed to comply with the

strict requirements of La. R.S. 47:1565, such that the time delays contained therein

did not begin to run. International Rivercenter concluded that it thus timely filed

its Petition with the Board and that the Board possessed subject matter jurisdiction

to consider the merits of the Petition. Thereafter, the Board held a hearing on the

Department’s Exceptions.

NOVEMBER 3, 2021 HEARING ON THE EXCEPTIONS

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International Rivercenter Lessee, L.L.C. v. Kimberly L. Robinson, in Her Capacity as Secretary of the Department of Revenue, State of Louisiana, Counsel Stack Legal Research, https://law.counselstack.com/opinion/international-rivercenter-lessee-llc-v-kimberly-l-robinson-in-her-lactapp-2022.