Jimenez v. Dept. of Rev.

CourtOregon Tax Court
DecidedJanuary 5, 2021
DocketTC-MD 200039G
StatusUnpublished

This text of Jimenez v. Dept. of Rev. (Jimenez v. Dept. of Rev.) 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
Jimenez v. Dept. of Rev., (Or. Super. Ct. 2021).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Income Tax

MICKEY JIMENEZ ) and THERESA L. JIMENEZ, ) ) Plaintiffs, ) TC-MD 200039G ) v. ) ) DEPARTMENT OF REVENUE, ) ORDER DENYING PLAINTIFFS’ State of Oregon, ) MOTION FOR SUMMARY JUDGMENT ) AND GRANTING DEFENDANT’S Defendant. ) MOTION FOR SUMMARY JUDGMENT

At issue on cross-motions for summary judgment is Plaintiffs’ claim that Defendant lacks

authority to adjust their zero returns for 2016, 2017, and 2018. The court finds for Defendant

and awards the frivolous appeal penalty.

I. FACTS

Plaintiffs claimed zero income on their 2018 Oregon and federal returns and on Oregon

amended returns filed for 2016 and 2017. The IRS accepted Plaintiffs’ 2018 federal return and

refunded them $8,020 of W-2 and 1099 withholding with interest. (Compl at 11.)

According to Defendant, Plaintiffs’ W-2 forms for 2016, 2017, and 2018 report Oregon-

source income. Plaintiffs allege that their “private sector earnings” for those three years

generated no taxable income.

Defendant adjusted Plaintiffs’ 2018 Oregon wages from zero to $129,577 and denied

Plaintiffs’ amended returns for 2016 and 2017. It issued a Notice of Deficiency regarding the

first of those actions and a Notice of Amended Return Denial regarding each of the other two.

Details of the notices are included below in the analysis where relevant.

///

ORDER DENYING PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT AND GRANTING DEFENDANT’S MOTION FOR SUMMARY JUDGMENT TC-MD 200039G 1 of 5 Plaintiffs request that the court reverse Defendant’s adjustments to their 2018 return and

their 2016 and 2017 amended returns. Defendant requests that the court uphold its

determinations and impose the frivolous appeal penalty.

II. ANALYSIS

The precise issue in this case is not whether Plaintiffs actually earned taxable income, but

rather whether Defendant had authority to adjust Plaintiffs’ returns. Although the Complaint’s

reference to “private sector earnings” not resulting in taxable income is reminiscent of the

frivolous argument that wages are not taxable income, Plaintiffs do not develop such an

argument. Cf. Combs v. Dept. of Rev., 331 Or 245, 248, 14 P3d 584 (2000) (holding that

argument “has no objectively reasonable basis in federal or state law”).

The court grants summary judgment motions where the documents on file show “there is

no genuine issue as to any material fact and that the moving party is entitled to prevail as a

matter of law.” TCR 47 C; TCR–MD 13 B.1

A. 2018 Taxable Income

Plaintiffs argue that Defendant’s notices do not meet an alleged formal requirement that

they be signed under penalty of perjury. In Plaintiffs’ view, “the Commissioner or other

authorized Revenue Officer” must either accept the income reported by a taxpayer on a return or

else find “an authorized official * * * who is competent and willing to assert credible, personal

knowledge” of additional income in a competing return. Plaintiffs claim that “[t]ax agencies

have no basis * * * by which they can evaluate or assign special significance to allegations by

third parties, such as those made on W-2s or 1099s.” Plaintiffs conclude that Defendant’s Notice

1 The references are to the Tax Court Rules (TCR) and the Tax Court Rules–Magistrate Division (TCR– MD).

ORDER DENYING PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT AND GRANTING DEFENDANT’S MOTION FOR SUMMARY JUDGMENT TC-MD 200039G 2 of 5 of Deficiency “is legally invalid and fictitious on its face” because it does not bear such a

signature. Plaintiffs summarily cite federal statutes and regulations pertaining to the IRS to

support their view.

Defendant is not the IRS, and Oregon law authorizes Defendant to adjust returns when it

determines in good faith there is a deficiency. ORS 305.265(2).2 Defendant must give notice

when it adjusts a return, but there is no requirement that its notice be signed. See id. Defendant

is empowered to evaluate returns and estimate income by examining required “books, papers,

records or memoranda bearing upon the matter.” ORS 314.425(1). In particular, the federal

form W-2 is suitable for substantiating compensation paid and taxes withheld. See ORS

316.202.

Adjusting Plaintiffs’ return based on examination of their W-2 forms is well within the

scope of Defendant’s authority, and Defendant is under no obligation to generate a signed return

of its own. Cf. ORS 305.265(2). Plaintiffs’ argument to the contrary is without basis in law.

B. 2016 and 2017 Amended Return Denials

Plaintiffs apply the same argument and authority against the denial of their 2016 and

2017 amended returns, claiming that Defendant “by law can only dispute” Plaintiffs’ returns by

way of its own “sworn information returns for the relevant tax periods[.]”

A timely filed amended return showing a refund due is a “claim for refund” under ORS

305.270(2). Upon receiving such a claim, Defendant must “either refund the amount requested

or send to the claimant a notice of any proposed adjustment to the refund claim, stating the basis

upon which the adjustment is made.” ORS 305.270(3). The notice of proposed adjustment must

2 The court’s references to the Oregon Revised Statutes (ORS) are to 2017. The relevant statutes did not change substantively between 2015 and 2017.

ORDER DENYING PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT AND GRANTING DEFENDANT’S MOTION FOR SUMMARY JUDGMENT TC-MD 200039G 3 of 5 be accompanied by a statement explaining appeal rights, but there is no requirement that it be

signed. See ORS 305.270(4)(a).

Here, Defendant responded to each of Plaintiffs’ amended return filings with a notice

captioned “Notice of Amended Return Denial.” Each of those notices contained a paragraph

explaining that Plaintiffs’ amended return was “not valid” because it “remov[ed] from taxable

income the wages [Plaintiffs] earned during the year.” The notices each contained information

explaining Plaintiffs’ right to appeal.

Defendant’s two notices appear to meet the requirements of ORS 305.270 for notices of

proposed adjustment; at least, their lack of signatures does not invalidate them.3 There is no

further legal requirement for Defendant to generate a sworn return of its own before adjusting a

refund claimed in an amended return. Plaintiffs’ argument to the contrary lacks any basis in law.

C. Frivolous Appeal Penalty

“Whenever it appears to the Oregon Tax Court that proceedings before it have been instituted or maintained by a taxpayer primarily for delay or that the taxpayer’s position in such proceeding is frivolous or groundless, a penalty in an amount not to exceed $5,000 shall be awarded to the Department of Revenue by the Oregon Tax Court in its judgment. * * *.

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Related

Combs v. Department of Revenue
14 P.3d 584 (Oregon Supreme Court, 2000)

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Jimenez v. Dept. of Rev., Counsel Stack Legal Research, https://law.counselstack.com/opinion/jimenez-v-dept-of-rev-ortc-2021.