Korkeakoski v. Dept. of Rev.

CourtOregon Tax Court
DecidedApril 7, 2025
DocketTC-MD 240154N
StatusUnpublished

This text of Korkeakoski v. Dept. of Rev. (Korkeakoski 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
Korkeakoski v. Dept. of Rev., (Or. Super. Ct. 2025).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Income Tax

ESA E. KORKEAKOSKI ) and NICOLE M. KORKEAKOSKI, ) ) Plaintiffs, ) TC-MD 240154N ) v. ) ) DEPARTMENT OF REVENUE, ) State of Oregon, ) ) Defendant. ) DECISION

This matter came before the court on Defendant’s Motion to Dismiss (Motion), filed

April 4, 2024, alleging that Plaintiffs are appealing their own 2019 tax return and are, therefore,

not aggrieved, and that Plaintiffs’ attempted election to expense an asset is untimely. During the

case management conference held June 11, 2024, the parties agreed to a written briefing

schedule on Defendant’s Motion. In accordance with that schedule, Plaintiffs filed a written

response on June 21, 2024. Defendant filed a written reply on July 10, 2024.1 Because the

parties briefed both the procedural issue of whether Plaintiffs are aggrieved and the substantive

issue of whether Plaintiffs may expense an asset, the court construes the briefings as cross

motions for summary judgment.2 This matter is now ready for the court’s determination.

///

1 Defendant labeled its reply as an “Answer,” (Def’s Reply at 1), but the court construes it as a reply in accordance with briefing schedule established during the case management conference. (See Journal Entry, June 11, 2024.) Generally, an “answer” is a responsive pleading to a complaint. See Tax Court Rule-Magistrate Division 2 A (describing usual titles of responsive pleadings). 2 Compare Tax Court Rule (TCR) 21 A (listing the defenses that may, at the option of the pleader, be made by motion to dismiss), with TCR 47 A-C (describing when and how parties may move for summary judgment).

DECISION TC-MD 240154N 1 I. STATEMENT OF FACTS

Plaintiffs’ income tax return for the 2019 tax year was selected for audit. (Ptfs’ Ltr at 6,

Jun 21, 2024.) During the audit, Plaintiffs requested that the auditor change the treatment of a

printer lease to allow a section 179 deduction, but “[t]he auditor accepted [Plaintiffs’] rent and

lease expenses as filed.” (Id. at 1, 12.) The audit resulted in a net increase of Schedule C income

by $30,094, increased tax, and imposition of a substantial understatement penalty. (Id. at 6.)

Plaintiffs appealed Defendant’s Notice of Deficiency and requested a conference, “objecting to

the adjustments to gross receipts, depreciation, supplies, and other expenses.” (Id.)

During conference, Plaintiffs “stated that on the original return, the payments on the

printer were treated as lease payment expenses because the agreement with [the lessor] was

interpreted to be an operating lease[.]” (Ptfs’ Ltr at 12, Jun 21, 2024.) Plaintiffs further stated

that “it wasn’t until the audit that [Plaintiffs] realized it was a capital lease and expense * * *.”

(Id.) Plaintiffs “proposed to eliminate the $5,853 in rent and lease payments and capitalize the

printer” instead, so that the equipment could be depreciated under Internal Revenue Code (IRC)

section 179. (Id. at 12, 1.) The conference officer declined the proposal, “holding [Plaintiffs] to

[their] original reporting position.” (Id. at 12.) The conference officer made other adjustments,

resulting in a decrease to Schedule C income of $8,058 from the amount determined at audit and

removal of the substantial understatement penalty. (Id. at 13, 18.) A Notice of Assessment was

issued following the conference. (See id.; Compl at 3.)

Plaintiffs filed this appeal, challenging Defendant’s Notice of Assessment for the 2019

tax year. (Compl at 1, 3.) Plaintiffs claim Defendant is in error because Defendant “has treated

a capital lease as an operating lease and failed to properly classify the asset as such.” (Id. at 1.)

Plaintiffs request that the court classify the printer lease “as a capital lease and record

DECISION TC-MD 240154N 2 depreciation expense as is available, up to the total cost of $33,768.51.” (Id.)

Defendant offers a two-part response to Plaintiffs’ Complaint, part procedural and part

substantive. (See Def’s Mot at 1; Def’s Reply at 1.) On the procedural matter, Defendant

essentially argues that Plaintiffs are not aggrieved—and therefore do not have standing to bring

suit—“[b]ecause Plaintiff[s’] sole complaint is regarding their own filing.” (Def’s Mot at 1.)

Stated another way, Defendant argues that Plaintiffs are appealing their own tax return. On the

substantive matter, Defendant states that “[t]he 179 election must be made on Plaintiff[s’] first

income tax return or an amended return filed timely.” (Def’s Reply at 1.) Defendant argues that,

“[i]f Plaintiff[s] wanted to elect to expense the asset in the manner expressed in their complaint,

they needed to make the election in a timely manner per Treasury Regulation 1.179-5.” (Def’s

Mot at 1.)

II. ANALYSIS

The issues presented for the 2019 tax year are (1) whether Plaintiffs are aggrieved, and

(2) whether Plaintiffs may claim bonus depreciation under IRC section 179 for the cost of a

printer lease that Plaintiffs treated as an operating lease on their original return. The court grants

summary judgment where the documents on file show “there is no genuine issue as to any

material fact” and “the moving party is entitled to prevail as a matter of law.” TCR 47 C.

A. Whether Plaintiffs Are Aggrieved

To appeal to this court, a “person must be aggrieved by and affected by an act, omission,

order or determination of * * * [t]he Department of Revenue in its administration of the revenue

and tax laws of this state.” ORS 305.275(1)(a)(A).3 Defendant adjusted Plaintiffs’ 2019 return

resulting in additional tax due and Plaintiffs appealed from Defendant’s Notice of Assessment, as

3 References to the Oregon Revised Statutes (ORS) are to the 2017 edition.

DECISION TC-MD 240154N 3 contemplated by statute. See ORS 305.265(15) (stating appeal may be taken to this court from

any notice of assessment). At least initially, it appears Plaintiffs are aggrieved under the relevant

statutes. Yet, as Defendant notes, the only error Plaintiffs allege with respect to Defendant’s

conference decision (the basis for the Notice of Assessment) concerns an item that Defendant did

not adjust: a business expense claimed for a printer lease payment. Defendant argues that

Plaintiffs are, essentially, appealing their own tax return, rather than an adjustment made by

Defendant.

“[T]he income tax system is based on self-assessment. Under our system, taxpayers are

given a number of choices or elections[,]” including, for example, “the timing and methods of

claiming depreciation and other deductions.” Arnold v. Dept. of Rev., 12 OTR 69, 72 (1991). In

accordance with the concept of self-assessment, this court has held that a taxpayer is not

aggrieved by their own return. See, e.g., Beesley v. Dept. of Rev., TC-MD 021084C, 2003 WL

21235445 at *1 (Or Tax M Div Mar 18, 2003) (dismissing taxpayer’s appeal to change filing

status from that taken on original return because department did not adjust taxpayer’s return so

taxpayer was not aggrieved); Ruiz-Galicia v. Dept. of Rev., TC-MD 100768D, 2010 WL

3706449 at *1 (Or Tax M Div Sept 22, 2010) (dismissing taxpayer’s appeal of “self-assessed

state income tax for tax year 2005” due in part to “no appealable action”). A taxpayer wishing to

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