Metals USA Plates & Shapes Southeast, Inc. C/W O'Neal Steel Louisiana, LLC v. Louisiana Department of Revenue

CourtLouisiana Court of Appeal
DecidedMarch 21, 2018
DocketCA-0017-0699
StatusUnknown

This text of Metals USA Plates & Shapes Southeast, Inc. C/W O'Neal Steel Louisiana, LLC v. Louisiana Department of Revenue (Metals USA Plates & Shapes Southeast, Inc. C/W O'Neal Steel Louisiana, LLC v. Louisiana Department of Revenue) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Metals USA Plates & Shapes Southeast, Inc. C/W O'Neal Steel Louisiana, LLC v. Louisiana Department of Revenue, (La. Ct. App. 2018).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

17-699

METALS USA PLATES & SHAPES SOUTHEAST, INC.

C/W O’NEAL STEEL LOUISIANA, LLC

VERSUS

LOUISIANA DEPARTMENT OF REVENUE

**********

APPEAL FROM THE BOARD OF TAX APPEALS NO. 9342-D HONORABLE TONY GRAPHIA (ret.), CHAIRMAN

VAN H. KYZAR JUDGE

Court composed of Billy Howard Ezell, Van H. Kyzar, and Candyce G. Perret, Judges.

AFFIRMED. Nicole Gould Frey David R. Cassidy Breazeale, Sachse & Wilson, L.L.P. P. O. Box 3197 Baton Rouge, LA 70821-3197 (225) 387-4000 COUNSEL FOR PLAINTIFF/APPELLANT: O’Neal Steel Louisiana, LLC

Aaron Long Brandea P. Averett Antonio C. Ferachi Adrienne Quillen Louisiana Department of Revenue P. O. Box 4064 Baton Rouge, LA 70821-4064 (225) 219-2080 COUNSEL FOR DEFENDANT/APPELLEE: Louisiana Department of Revenue KYZAR, Judge.

O’Neal Steel Louisiana, LLC (O’Neal), appeals from the Board of Tax

Appeals’ judgment, which held that certain commercial purchases of fuels and

gases were not excluded from sales tax under La.R.S 47:301(10)(x) and dismissed

O’Neal’s refund claim for $3,423.33. For the following reasons, we affirm.

FACTS AND PROCEDURAL HISTORY

O’Neal, which has its principal place of business in Lafayette, Louisiana, is

engaged in the metals business, including welding and metals fabrication. O’Neal

purchased, and paid sales tax on, welding gases that are used as shielding gases in

the welding process. O’Neal filed a refund claim with the Louisiana Department

of Revenue (LDR) for sales taxes it paid for the period beginning January 2011

through February 2014, claiming various exemptions such as the Manufacturing,

Machinery, and Equipment exemption and the Fuels exemption, which it claims

includes welding gases. LDR allowed most of the refund claimed but denied the

portions for sales taxes paid on the purchase of welding gases. O’Neal then

appealed the ruling of LDR to the Board of Tax Appeals 1 (the Board). At the

hearing, O’Neal submitted evidence that sales taxes were in fact paid on O’Neal’s

purchases of welding gases. The parties stipulated that O’Neal filed a $10,066.07

refund claim for sales taxes paid, of which $9,250.32 was initially denied, but that

LDR thereafter allowed another $2,393.42. The parties further stipulated the sum

of $3,423.33 in sales taxes paid on fuel for which O’Neal continued to claim

entitlement to a refund. The Board held that commercial purchases of fuels and

1 The Board consolidated this matter with another taxpayer, Metals USA Plates & Shapes Southeast, Inc., which had an identical dispute except for the amount of the refund claimed. That matter has likewise been appealed but in a different appeal venue. gases were not excluded from tax under La.R.S. 47:301(10)(x) and dismissed

O’Neal’s refund claim for the $3,423.33. This appeal followed.

O’Neal asserts the following assignments of error:

1. It was reversible error to judicially repeal 2008 La. 2 nd Ext. Sess. Act 1 (Act 1), which excluded all commercial off-highway fuel purchases from tax, because simultaneous legislation, 2008 La. 2 nd Ext. Sess. Act 9 (Act 9), excluded only commercial purchases of butane and propane fuels from tax.

2. The trial court erred in finding Acts 1 and 9 are in conflict.

3. The trial court erred in failing to give effect to all laws passed by the legislature.

4. It is reversible error to tacitly repeal Act 1 without any attempt to harmonize it with Act 9.

OPINION

The resolution of this dispute hinges entirely on the interpretation of two

acts passed by the Louisiana Legislature in the same session, each applicable to the

purchase of the welding gases at issue here and certain exemptions from sales taxes

for those purchases. Act No. 1 of the 2008 Second Extraordinary Session,

excluded from tax any fuel or gas purchased, and Act No. 9 of the same session,

exempted only butane and propane gases. Each act attempted to amend and

reenact the same provision, La.R.S. 47:301(10)(x). The Board found that the latter

act tacitly repealed the first and denied O’Neal’s claim based upon that finding.

Thus, the sole issue presented to the Board was a legal one: whether the O’Neal

purchases of welding gases were exempt from sales tax under La.R.S.

47:301(10)(x).

Although a deferential standard of appellate review is applied to the factual

conclusions of an administrative tribunal such as the Board, the same is not true for

issues of law. “Questions of law, such as the proper interpretation of a statute, are

reviewed by [an appellate] court under the de novo standard of review.” Land v. 2 Vidrine, 10-1342, p.4 (La. 3/15/11), 62 So.3d 36, 39. “On legal issues, the

appellate court gives no special weight to the findings of the trial court, but

exercises its constitutional duty to review questions of law and renders judgment

on the record.” State, Through La. Riverboat Gaming Comm’n v. La. State Police

Riverboat Gaming Enf’t Div., 95-2355, p. 5 (La.App. 1 Cir. 8/21/96), 694 So.2d

316, 319. “Appellate review of a question of law involves a determination of

whether the lower court’s interpretive decision is legally correct.” Johnson v. La.

Tax Comm’n, 01-964, p. 2 (La.App. 4 Cir. 1/16/02), 807 So.2d 329, 331, writ

denied, 02-445 (La. 3/8/02), 811 So.2d 887.

On review of the district court’s judgment, no deference is owed by the court of appeal to factual findings or legal conclusions of the district court, just as no deference is owed by the Louisiana Supreme Court to factual findings or legal conclusions of the court of appeal. See La.Const. art. 5, § 5(C); Donnell v. Gray, 215 La. 497, 41 So.2d 66, 67 (1949).

Eicher v. La. State Police, Riverboat Gaming Enf’t Div., 97-121, p.6 (La.App. 1 Cir. 2/20/98), 710 So.2d 799, 803, n.5, writ denied, 98-780 (La. 5/8/98), 719 So.2d 51.

Prior to 2008, the law in question, La.R.S. 47:301(10)(x) (emphasis added),

provided that “[f]or purposes of the sales and use tax imposed by the state. . . the

terms ‘retail sale’ or ‘sale at retail’ shall not include the sale or purchase by a

consumer of any fuel or gas, including but not limited to butane and propane,

for residential use by the consumer.” During the 2008 Second Extraordinary

Session of the Louisiana Legislature, law makers attempted to expand the sales tax

exclusion for gases found in La.R.S. 47:301. Act No. 1 and Act No. 9 were both

introduced in the 2008 Second Extraordinary Session and both revised La.R.S.

47:301(10)(x); however, the revisions enacted by each Act arguably contradict

each other.

3 It is well established that in the case of conflict between two acts of the

legislature, it is the last expression of legislative will that controls. State v. St.

Julian, 221 La. 1018, 61 So.2d 464 (1952); Board of Ethics In Re Davies, 10-1339

(La.App. 1 Cir. 12/22/10), 55 So.3d 918. “There is no other reasonable rule that

could be applied to conflicting statutes passed at the same session of the legislature

than to hold that the later expression of the legislative will must govern.” St.

Julian, 61 So.2d at 466. Therefore, to determine whether O’Neal was exempt from

paying sales tax on its purchases, we must first ascertain whether the two acts are

irreconcilable.

On appeal, O’Neal asserts that it was error for the Board to find that the two

acts contradict each other.

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Metals USA Plates & Shapes Southeast, Inc. C/W O'Neal Steel Louisiana, LLC v. Louisiana Department of Revenue, Counsel Stack Legal Research, https://law.counselstack.com/opinion/metals-usa-plates-shapes-southeast-inc-cw-oneal-steel-louisiana-llc-lactapp-2018.