Municipality of Anchorage v. Alaska Distributors Co.

725 P.2d 692, 1986 Alas. LEXIS 388
CourtAlaska Supreme Court
DecidedSeptember 19, 1986
DocketNo. S-1047
StatusPublished
Cited by9 cases

This text of 725 P.2d 692 (Municipality of Anchorage v. Alaska Distributors Co.) is published on Counsel Stack Legal Research, covering Alaska Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Municipality of Anchorage v. Alaska Distributors Co., 725 P.2d 692, 1986 Alas. LEXIS 388 (Ala. 1986).

Opinion

RABINOWITZ, Chief Justice.

The parties dispute whether a municipality may retroactively tax a warehouse addition as “escaped property” when it timely assessed and taxed other improvements on the real property. We hold that the municipality may so tax the warehouse under the particular circumstances of this case.

FACTUAL AND PROCEDURAL BACKGROUND

Appellee Alaska Distributors Co. (ADCO) owns improved property in Anchorage. In 1979, ADCO built an addition worth just over $1 million to an existing warehouse located on the property. This addition doubled the warehouse floor space. Through an oversight, appellant Municipality of Anchorage did not include the value of the addition in tax assessments on improvements to the property for the four years from 1980-1983, inclusive.1 ADCO did not advise the municipality of the omission of the warehouse addition for the four tax years in question.

In 1984, the municipality discovered its error and sent ADCO retroactive tax bills for 1980-83. ADCO paid the taxes under protest. Following an unsuccessful appeal to the Municipal Board of Equalization, ADCO filed an action in the superior court seeking a refund of the taxes it had paid under protest. The superior court entered summary judgment for ADCO, concluding that the principle of finality barred the municipality’s attempt to collect back taxes. The municipality then brought this appeal.

[693]*693RETROACTIVE TAXATION OF “ESCAPED PROPERTY”

The municipality argues that the warehouse addition is “escaped property” which may be retroactively assessed and taxed. ADCO contends that the doctrine of finality bars reassessment because the assessment roll shows that the improvements on the property were taxed and the tax paid. The superior court concluded that the municipality may not reassess improvements which were actually valued and taxed in prior years.

The municipal tax assessor assesses property at its “full and true value” as of the first day of the tax year. AS 29.45.-110(a).2 The appraised value of land and improvements are stated separately on assessment notices. Anchorage Municipal Code 12.15.040(A) (hereinafter cited as “AMC”).3 The taxpayer must advise the assessor of any errors or omissions in the assessment, AS 29.45.180(a),4 and property omitted from the assessment roll is included in the supplementary roll. AS 29.45.-220.5 The six year statute of limitations for actions in the name of a political subdivision applies to the taxation of escaped properties. Alascom v. North Slope Borough, 659 P.2d 1175, 1179 (Alaska 1983); AS 09.10.120.6

We have twice discussed retroactive assessment and taxation. In Anchorage Independent School District v. Stephens, 370 P.2d 531 (Alaska 1962), the value of improvements on the taxpayer’s property was mistakenly assessed to neighboring land. When the assessor discovered the error, he reassessed the land for two previous tax years, but never notified or billed the taxpayer. Subsequent assessment notices failed to disclose any delinquency due to the retroactive reassessment. The taxpayer sold the property and the new owner paid taxes without knowledge of the asserted deficiency. A tax foreclosure sale occurred eight months after the transfer; the new owner discovered the tax sale over a year after it occurred. We invalidated the tax foreclosure sale because the assessor had no power to increase the assessed valuation once a point of finality was reached. Id. at 533. In that case, the point of finality occurred when the district exercised the power to tax and the taxpayer concurred by tendering payment. Id. at 532-33. The new owner was entitled to rely on subsequent assessment notices which did not disclose any delinquency. Id. at 532.

[694]*694In Alascom v. North Slope Borough, 659 P.2d at 1177 n. 4, we concluded that former AS 29.53.150 7 permitted a local taxing authority to assess and tax escaped property. We distinguished Stephens, explaining that that decision bars only retroactive revaluation of property already taxed, whereas the borough was attempting to value for the first time property which had escaped assessment and taxation entirely. Id. at 1178-79 & n. 9.

Neither decision answers the specific question presented here: whether an addition to real property is “escaped property” subject to retroactive assessment when other improvements on the land were assessed and taxed.

The courts in other jurisdictions are divided on this question. When all improvements on the land are omitted, some jurisdictions allow retroactive taxation. Korash v. Mills, 263 So.2d 579, 580-81 (Fla.1972); Mueller v. Mercer County, 60 N.W.2d 678 (N.D.1953); Chew v. Board of Assessment Appeals, 673 P.2d 1028 (Colo.App.1983). These courts believe that the assessor is not attempting to correct an error in judgment resulting in undervaluation; rather, the assessor is assessing for the first time property which escaped assessment entirely. Korash, 263 So.2d at 581. However, other jurisdictions preclude later assessment, reasoning that the property as a unit consisting of the land and improvements has already been taxed. Leyh v. Glass, 508 P.2d 259, 262-63 (Okla.1973); In re Westward Look Development Corp., 138 Ariz. 88, 673 P.2d 26, 27-28 (Ariz.App.1983); Board for Assessment and Revision of Taxes v. Philadelphia Electric Co., 10 Pa.Cmwlth. 382, 308 A.2d 627, 631-32 (1973). The omission of the improvements, therefore, constitutes an undervaluation of the tax on the entire property which cannot be reassessed. Leyh, 508 P.2d at 263; Westward Look, 673 P.2d at 28.

When only a portion of the improvements escapes, the courts are again split. Some jurisdictions allow retroactive assessment of property or improvements omitted in part. California originally adhered to the rule that escape provisions apply only when there has been no assessment of improvements at all. Stafford v. Riverside County, 155 Cal.App. 474, 318 P.2d 172, 174 (1957). In Bauer-Schweitzer Malting Co. v. City and County of San Francisco, 8 Cal.3d 942, 106 Cal.Rptr. 643, 506 P.2d 1019, 1022-23 (1973), the court disapproved Stafford. There the court permitted reassessment of personal property to correct favored treatment resulting from taxation at an impermissibly low assessment ratio. The court ruled that the use of the low ratio constituted an escape. Id. at 1022. Other jurisdictions preclude retroactive assessment when any part of the improvements is taxed.

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725 P.2d 692, 1986 Alas. LEXIS 388, Counsel Stack Legal Research, https://law.counselstack.com/opinion/municipality-of-anchorage-v-alaska-distributors-co-alaska-1986.