Linnehan Leasing v. State Tax Assessor

CourtSuperior Court of Maine
DecidedMarch 28, 2005
DocketKENap-03-46
StatusUnpublished

This text of Linnehan Leasing v. State Tax Assessor (Linnehan Leasing v. State Tax Assessor) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Linnehan Leasing v. State Tax Assessor, (Me. Super. Ct. 2005).

Opinion

STATE OF MAINE SUPERIOR COURT

KENNEBEC, SS. . CIVIL ACTION DOCKET NO.: AP-03-46 hg

LINNEHAN LEASING,

Petitioner Vv. DECISION ON APPEAL STATE TAX ASSESSOR, Respondent

This matter comes before the court on cross motions for summary judgment on the petition of Linnehan Leasing (“Linnehan”) from a decision of the State Tax Assessor (“the Assessor”) pursuant to 36 M.R.S.A. §151. Pursuant to the statute, this court must conduct a de novo hearing and make a de novo determination of the merits of the case.

Factual and Procedural Background

The tax assessment at issue in this case involves a period from May 1, 1999 - through December 31, 2001. During that time, Linnehan was (and still is) in the business of selling used cars from locations in Bangor and elsewhere in down cast Maine. Linnehan was registered as a Maine retailer under the Maine Sales Use Tax Law’, filed monthly sales tax returns, and remitted sales tax on a monthly basis.

Atlantic Acceptance Corporation (“Atlantic”) is a finance company that works exclusively with Linnehan. Atlantic and Linnehan share the same customers, and Atlantic only finances vehicles purchased from Linnehan. Additionally, Atlantic and

Linnehan share owners, officers, directors, office space, telephones, computers, a website

] 36 M.R.S.A. §1751 ET SEQ.

and signage. However, these entities are organized as separate corporations each maintaining it’s own books and filing separate federal and state tax returns.

Customers of Linnehan/Atlantic often finance the entire purchase of an automobile includmg the sales tax. Once Atlantic approves the credit of Linnehan’s customer, the customer enters into a retail sales finance agreement, promising to repay to Linnehan all finance costs plus interest. By prearrangement, Linnehan immediately assigns the finance agreement to Atlantic in return for a percentage of the amount financed, thereby obligating the customer to make their loan payments to Atlantic.

The issue in the present case concerns sales tax credits taken by Linnehan for sales tax paid at the time of sale for the purchase of vehicles by buyers who later default on their loans. In these circumstances, the vehicles are repossessed and resold. However, in each of the cases in the present appeal, even after the repossession and sale of the collateral, an unpaid balance remained owing. After certain time and effort had past, if the balance owed remained unpaid it was charged off as worthless on the books of Atlantic and deducted for income tax purposes.

Even though these bad debts were charged off on Atlantic’s books rather than Linnehan’s, Linnehan would claim a tax credit for the financed but unreimbursed sales tax when it filed subsequent sales tax returns. Linnehan believes that based on the plain language of 36 M.R.S.A. §1811-A it is entitled to take these credits

The present controversy arises out of the Assessor’s determination that the petitioner had impermissibly taken the credits for the tax portion of these worthless accounts for the period in question. These credits total $334,134.51 in sales tax, $70,294.30 in-interest and a negligence penalty of $84,490.14. After the assessment, Linnehan requested reconsideration, which resulted in the Assessor upholding the initial assessment. Linnehan then filed the present appeal pursuant to 36 M.R.S.A. §151 and Maine Rules of Civil Procedure 80C.

Discussion

This appeal raises two primary questions. First, how should the tax credit permitted by 36 M.R.S.A. §1811-A be applied within the narrow, undisputed facts of this case? Second, should Linnehan be required to pay negligence penalties? Although,

procedurally this is an appeal from a decision of the Assessor, this appeal is one with a

different twist in light of the statutory requirement noted above that the court conduct a de novo hearing and make a de novo determination of the merits. 36 M.R.S.A. $151. The court is satisfied that the parties are able to agree to sufficient undisputed facts as part of the summary judgment process to allow the court to make such de novo determination. The issues will be discussed separately. I. Merits The statute in question, §1811-A, reads as follows:

The tax paid on sales represented by accounts charged off as worthless may be credited against the tax due on a subsequent report filed within three years of the charge-off, but, if any such accounts are thereafter collected by the retailer, a tax shall be paid upon the amounts collected.

This provision has been interpreted in a similar, but different context to mean the Legislature intended that the tax credit could be claimed only by the retailer, which sold the vehicle and paid the sales tax in the first place. DaimlerChrysler Services North America v. State Tax Assessor, 2003 ME 27, 817 A. 2d 862. In other words, it is the retailer sold the vehicle, which can apply for the tax credit, not a subsequent holder of the note. Linnehan does not dispute the holding in DaimlerChrysler, but attempts to distinguish the factual background of the two decisions. In DaimlerChrysler, the purchaser of the paper was a large national financing company, doing business with many retail sellers. There is no indication that the company had any other relationship with these retailers. There was no question that DaimlerChrysler was not the retailer or part of the retailer and the Supreme Judicial Court held that it was not entitled to the tax credits. In contrast, the relationship between Linnehan and Atlantic is so close that they could be considered the business equivalent Siamese twins, joined at the hip. Atlantic would not exist without Linnehan and Linnehan does its finance business only with Atlantic. Although separate entities for some purposes, the evidence of shared owners, officers, directors, office space and general day-to-day business are convincing evidence that the two entities should be considered the same and as the joint “retailer” under this narrow application of §1811-A. Other evidence, which the court finds persuasive in this

regard, is the fact that the State itself, through the Attorney General, has recently argued

that Linnehan and Atlantic must be considered as one entity for purposes of unrelated regulatory litigation.” Support for this interpretation is also found in the definitional portions of the

ects.

statute. For purposes of the sale and use tax, “”retailer” means a person who makes retail sales...” 35 M.R.S.A. §1752 (10). In turn, “person” includes any individual, firm, co- partnership, association, society, club, corporation, estate, trust, business trust, receiver,

assignee or any other group or combination acting as a unit...” 36 M.R.S.A. §1752(9)

(1990) (emphasis provided)’ Therefore, as such “other group or combination acting as a unit”, Linnehan/Atlantic was the retailer. The court is satisfied that this application of §1181-A is “unmistakably within the spirit and intent of the statute”. DaimlerChrysler at paragraph 7, While the Supreme Judicial Court found that DaimlerChrysler was nota retailer for this purpose, Linnehan/Atlantic, together, fit within that definition.

I]. Negligence/Penalties.

The second issue concerns whether the negligence penalties imposed by the Assessor were proper. Under the statute, in order to be subject to these penalties, the petitioner must have failed “...to make a reasonable attempt to comply with provisions of this Title or rules issued pursuant to this Title”. 36 M.R.S.A. §187-B (3-A).

Linnehan asserts that no applicable rules have been issued pursuant to Title 36 and instructional bulletins are not rules for this purpose. Since the court has already

concluded that the petitioner’s reading of the credit statute was correct, it is difficult to

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Related

DaimlerChrysler Services North America, LLC v. State Tax Assessor
2003 ME 27 (Supreme Judicial Court of Maine, 2003)

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