Mack v. Dept. of Rev.

25 Or. Tax 179
Oregon Tax Court·Decided November 8, 2022·No. TC 5437·Published

Opinion

No. 11 November 8, 2022 179

IN THE OREGON TAX COURT REGULAR DIVISION

George E. MACK and Anna H. Mack, Plaintiffs, v. DEPARTMENT OF REVENUE, State of Oregon, Defendant. (TC 5437) On its motion for summary judgment under Tax Court Rule 47, Defendant Department of Revenue argued for the dismissal of Plaintiffs’ complaint because Plaintiffs did not pay “the tax assessed, and all penalties and interest due” before filing their complaint in the Regular Division and therefore did not satisfy ORS 305.419(1). In response, Plaintiffs argued that the assessment for the tax year at issue, 2016, was paid because Defendant held an overpayment, sufficient to pay the 2016 assessment, made by Plaintiffs for a subsequent tax year. Plaintiffs also argued that the overpayment had been “designated” for the 2016 assess- ment and that Plaintiffs subjectively believed that the 2016 tax had been paid. Granting Defendant’s motion, the court concluded that under OAR 150-314- 0248(2), Defendant could not apply an overpayment to satisfy a different year’s tax assessment when that other year’s assessment was on appeal. Further, the court found that Defendant’s correspondence to Plaintiffs created no reasonable inference that the overpayment had been applied to the 2016 assessment, nor does a taxpayer’s subjective belief satisfy the requirement under ORS 305.419(1).

Oral argument on Defendant’s motion for summary judg- ment was held remotely on August 10, 2022. Kevin P. O’Connell, Hagen O’Connell & Hval LLP, Portland, filed a response and argued the cause for Plaintiffs. Patrick L. Rieder, Assistant Attorney General, Department of Justice, Salem, filed the motion and argued the cause for Defendant. Decision rendered November 8, 2022. ROBERT T. MANICKE, Judge. I. INTRODUCTION This personal income tax case is before the court on Defendant’s motion for summary judgment under Tax Court Rule (TCR) 47. Plaintiffs oppose the motion but have 180 Mack v. Dept. of Rev.

not cross-moved. Defendant argues that Plaintiffs failed to pay “the tax assessed, and all penalties and interest due * * * on or before the filing of [their] complaint with the regu- lar division of the Oregon Tax Court * * *.” ORS 305.419(1).1 II. FACTS Defendant has submitted declarations and exhibits, together with the complaint, support the following factual narrative. A. Facts Related to Tax Year 2016 On or about October 15, 2017, Plaintiffs paid Defendant by check $22,003, which was the amount shown on their return for tax year 2016. On May 6, 2019, Defendant sent Plaintiffs a letter stating that Defendant was commenc- ing an audit of their return for tax year 2016. 1. March 9, 2020: Notice of Deficiency for Tax Year 2016 After the audit, Defendant issued a notice of defi- ciency, on March 9, 2020, adjusting Plaintiff’s 2016 income by denying certain business expense deductions they had claimed, and determining a deficiency of $24,901 in tax to pay, plus a 20-percent underpayment penalty of $4,980 and interest. The notice of deficiency also stated: “If you do not pay the balance within 30 days from the return’s due date or the date of this notice, whichever is later, a 5 percent pen- alty will be added.” A statement of account that Defendant issued to Plaintiffs the same day as the notice of deficiency includes a table that shows the following: Period Tax Penal- Interest Refund/ Credit Balance Ending ties/Fees Offset Dec 31, $44,868.00 $5,978.35 $4,931.00 $0.00 -$22,003.00 $33,774.35 2016

The amount of $44,868 in the “Tax” column in the statement of account corresponds with the “tax to pay” amount “per audit” in the notice of deficiency, which apparently means the total amount of tax due for the year, before applying 1 References to the Oregon Revised Statutes (ORS) and to the Oregon Administrative Rules (OAR) are to the 2021 editions unless otherwise indicated. Cite as 25 OTR 179 (2022) 181

any payment already made. The amount of -$22,003 in the “Credit” column corresponds with the amount Plaintiffs paid when they filed their return. 2. September 10, 2020: Notice of Assessment for Tax Year 2016 On September 10, 2020, Defendant issued its notice of assessment for the total amount of $35,776.66. The notice of assessment includes the following table: Period Tax Penalties/ Interest Refund/ Balance Ending Fees Offset Dec 31, $24,901 $6,225.05 $4,655.46 $0.00 $35,776.66 2016

The amount of $24,901 in the “Tax” column in the notice of assessment corresponds with the deficiency amount stated in the March 9, 2020, notice of deficiency. However, the court observes that the “Tax,” “Penalties/Fees” and “Interest” amounts shown add up to $35,781.51, not the $35,776.66 amount shown. A statement of account that Defendant issued to Plaintiffs the same day as the notice of assessment includes a table that shows the following: Period Tax Penal- Interest Refund/ Credit Balance Ending ties/Fees Offset Dec 31, $44,868.00 $7,223.40 $5,688.26 $0.00 -$22,003.00 $35,776.66 2016

The above amounts add up; the balance of $35,776.66 is the sum of the other amounts shown. 3. September 29, 2020: Appeal to Magistrate Division for Tax Year 2016 On or about September 29, 2020, Plaintiffs appealed the tax year 2016 assessment by filing a complaint in the Magistrate Division. The magistrate issued a decision on January 24, 2022. The decision upheld Defendant’s disal- lowance of certain deductions Plaintiffs had claimed, but the decision granted Plaintiffs’ appeal in part, ordering Defendant to reduce the assessment to reflect the court’s allowance of $115,600 of previously disallowed expense deductions. 182 Mack v. Dept. of Rev.

4. February 10, 2022: Appeal to Regular Division for Tax Year 2016 On or about February 10, 2022, Plaintiffs filed their complaint in this division of the court to appeal from the mag- istrate’s decision. On March 23, 2022, counsel for Plaintiffs sent a letter to Defendant’s counsel that, among other things, asked for a computation of the “amount necessary to have standing” for tax year 2016. On April 21, 2022, counsel for Plaintiffs apparently sent another letter, suggesting set- tlement. On May 26, 2022, counsel for the Department sent Plaintiffs’ counsel an email stating, in part, that Defendant had decided to not challenge the expenses that the magis- trate had ordered the Department to allow as deductions. In the same email, counsel for Defendant stated that the “payoff amount” for tax year 2016 was $21,060.27. 5. June 7, 2022: Payment of Assessment for Tax Year 2016 Except for the $22,003 paid with their tax return, Plaintiffs’ only payment for tax year 2016 was by check dated June 7, 2022, in the amount of $35,910. Defendant has not asserted that the amount paid was less than the full amount of tax, penalty and interest assessed. B. Facts Related to Tax Years 2019, 2020 and 2021 Between the March 9, 2020, notice of deficiency and the June 7, 2022, payment for tax year 2016, the following occurred. 1. January 20, 2021: Plaintiffs File Late and Overpay ($63,237) for Tax Year 2019 Plaintiffs filed their return for tax year 2019 on or about January 20, 2021, several months after the extended due date. They overpaid. Plaintiffs initially sought to apply $63,237 of the tax year 2019 overpayment to tax year 2020, entering the amount of the overpayment on line 31 of their return for tax year 2020. Defendant, however, treated Plaintiff’s request Cite as 25 OTR 179 (2022) 183

as a request to apply the refund to the next “open estimated tax account.” See OAR 150-316-0480 (procedure for apply- ing overpayments).

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