Maillard v. Dept. of Rev.

CourtOregon Tax Court
DecidedApril 3, 2023
DocketTC-MD 210345N
StatusUnpublished

This text of Maillard v. Dept. of Rev. (Maillard 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
Maillard v. Dept. of Rev., (Or. Super. Ct. 2023).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Income Tax

KEVIN C. MAILLARD ) and RHONDA MAILLARD, ) ) Plaintiffs, ) TC-MD 210345N ) v. ) ) DEPARTMENT OF REVENUE, ) State of Oregon, ) ) Defendant. ) DECISION

Plaintiffs appealed Defendant’s Notices of Assessment, dated July 13, 2021, for the 2015

and 2016 tax years. A trial was held remotely on November 17, 2022. Plaintiffs each appeared

and testified on their own behalf. Dane Palmer (Palmer), tax auditor, appeared and testified on

behalf of Defendant. Plaintiffs offered an unlabeled packet of documents totaling 293 pages.

Palmer stated that he had not received Plaintiffs’ documents. Plaintiffs’ certificate of service

listed two addresses for Palmer: one in Salem and one in Eugene. Plaintiffs clarified that they

mailed the exhibits to the Salem address, although Defendant’s Answer lists the Eugene address.

Many of Plaintiffs’ documents overlapped with Defendant’s Exhibits, 1 so the court admitted and

relied upon Defendant’s Exhibits A to G (tax year 2015) and A to E (tax year 2016).

I. STATEMENT OF FACTS

Rhonda Maillard testified to the following: In 2007, Plaintiffs purchased a home located

on Terra Lane in Veneta, Oregon. (See Def’s Ex A at 9.) Plaintiffs ran their side business, Whip

It Light Rods, out of the Terra Lane property for some period of time through December 2013.

To the extent Plaintiffs’ exhibit packet included any exhibit labels, they were the labels used by 1

Defendant. (See, e.g., Exs B, E, F.) Other documents in Plaintiffs’ packet were documents filed in this case, such as the Complaint, notices, correspondence between the parties, and court-issued documents.

DECISION TC-MD 210345N 1 (See id.; Def’s Ex D at 15.) Plaintiffs moved out of the Terra Lane property in December 2013

and into a new home. (Def’s Ex D at 15.) Plaintiffs listed the Terra Lane property for sale in

October 2013. (Id.) Thereafter, on the advice of a financial advisor, they reached out to their

mortgage lender and received preapproval to sell the property by short sale. (See id.) In 2015,

Plaintiffs sold the Terra Lane property by short sale. (See Def’s Ex B at 11-15.)

The parties dispute the impact of those events on Plaintiffs’ 2015 and 2016 Oregon

income tax liabilities. Rhonda testified that she prepared and filed both Plaintiffs’ 2015 and

2016 returns using TurboTax. She acknowledged making several mistakes.

A. Tax Year 2015

Due to a lack of supporting documentation, Defendant disallowed Plaintiffs’ Schedule C

business expenses ($8,509 for a home office and $4,887 for depreciation) associated with an

LED Lit Whip Manufacturing business. (Def’s Ex A at 4; Ex G at 3.) The address listed for that

business is Plaintiffs’ new home, not the Terra Lane property. (See id.) Also due to a lack of

documentation, Defendant disallowed a $38,782 loss that Plaintiffs reported on the sale of the

Terra Lane property and determined that Plaintiffs realized a gain of $22,011 on that sale. (Def’s

Ex G at 3.) Based on a 1099-C issued to Plaintiffs reporting a forgiveness of debt associated

with the Terra Lane short sale, Defendant determined Plaintiffs received other income of

$119,791. (Id. at 4.) Finally, Defendant made various adjustments to Plaintiffs’ Schedule A:

increasing deductions for real estate taxes and mortgage interest to include amounts claimed on

Schedule C, and disallowing employee business expenses (primarily mileage) due to lack of

substantiation. (Id.) At trial, Plaintiffs declined to pursue their claim for employee business

expenses. Defendant asserted that Plaintiffs’ Schedule E expenses associated with the Terra

Lane property should be disallowed based on their new position that it was a principal residence.

DECISION TC-MD 210345N 2 1. Amended return

Rhonda testified that Plaintiffs attempted to resolve several of the aforementioned

disputes by submitting an amended return to Defendant, but their return was rejected. (See Def’s

Ex D at 20 (Plaintiffs’ email to Defendant dated January 1, 2020, referenced an attached

amended return and asserted “we are still able to send in an amendment per Oregon tax law”).)

Her email explained that the amended return removed auto mileage and related expense

reimbursements from Kevin’s employer, and claimed expenses associated with the business use

of 800 square feet of their home. (Id.) She did not understand why Defendant rejected

Plaintiffs’ amended return and testified that, at one point, Palmer stated to her that Defendant

could not accept the return because of the open appeal in court.

2. Cancellation of indebtedness income

Defendant adjusted Plaintiffs’ 2015 tax return to include $119,791 of “other income.”

(See Def’s Ex G at 4.) Defendant contends that, as a result of the short sale of Plaintiffs’ Terra

Lane home, a Form 1099-C was issued by Freedom Mortgage for the Forgiveness of Debt in the

amount of $119,791, that “[t]he forgiveness of [d]ebt is taxable” as “other income[,]” and that

Plaintiffs did not include such income on their 2015 return. (See Def’s Ex E at 2; Def’s Ex C at

4.) Plaintiffs allege that they never received a Form 1099-C. (Def’s Ex D at 15.) However,

Plaintiffs’ IRS transcript indicates that a Form 1099-C was issued. (See Def’s Ex E at 2.)

Plaintiffs argue that because the Terra Lane home was their principal residence within the

meaning of the Mortgage Forgiveness Debt Relief Act of 2007, they “should not be required to

pay tax on the forgiven amount of the short sale.” (Def’s Ex D at 15-16. 2)

2 Plaintiffs used the term “primary residence” but the Mortgage Forgiveness Debt Relief Act (discussed below) uses the term “principal residence,” so the court defers to the language in the Act.

DECISION TC-MD 210345N 3 3. Loss reported on sale of business property

Rhonda testified that Plaintiffs had previously used a portion of the Terra Lane property

to run their side business, but maintains that the property was their principal residence, rather

than a business property. 3 Despite that characterization, Plaintiffs reported a $38,782 loss for the

sale of the Terra Lane property on Form 4797 – Sales of Business Property. (Def’s Exs A at 1,

9; G at 3.) Defendant determined that Plaintiffs’ Form 4797 should instead reflect a gain of

$22,011, based on the sale price compared to the basis at the time the residence was converted to

business property, the end of 2013. (See Def’s Ex C at 3-4.)

4. Loss deduction for rental real estate

On Schedule E Part I – Income or Loss From Rental Real Estate and Royalties, Plaintiffs

reported a total rental real estate loss of $25,013 for the Terra Lane property. (Def’s Ex A at 6,

9.) The loss is based on expenses of $13,500 in commissions; $900 in insurance; $4,650 in

depreciation; and $5,963 in closing costs. (Id. at 6.) The parties dispute whether the Terra Lane

property was ever used as a rental property. Rhonda testified that she erroneously reported the

loss on Schedule E and that Terra Lane was never a rental property. Palmer testified that, during

a prior phone call with Plaintiffs, they told him that the property had been converted to a rental.

(See also Def’s Ex C at 3 (“In a conversation on January 27, 2021[,] Rhonda stated that the home

was converted into a rental house at the end of 2013”).) Palmer testified that he never found any

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