N.C. Dep't of Revenue v. Clifton

2022 NCBC 20
CourtNorth Carolina Business Court
DecidedApril 28, 2022
Docket21-CVS-11892
StatusPublished

This text of 2022 NCBC 20 (N.C. Dep't of Revenue v. Clifton) is published on Counsel Stack Legal Research, covering North Carolina Business Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
N.C. Dep't of Revenue v. Clifton, 2022 NCBC 20 (N.C. Super. Ct. 2022).

Opinion

N.C. Dep’t of Revenue v. Clifton, 2022 NCBC 20.

STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION WAKE COUNTY 21 CVS 11892

N.C. DEPARTMENT OF REVENUE,

Petitioner, ORDER AND OPINION ON v. PETITION FOR JUDICIAL REVIEW

GRETA ANN CLIFTON,

Respondent.

1. THIS MATTER is before the Court upon Petitioner North Carolina

Department of Revenue’s (the “Department” or “Petitioner”) Petition for Judicial

Review (“Petition,” ECF No. 3), of the Final Decision and Amended Final Decision

(except when referred to separately, “Final Decision”) issued by the North Carolina

Office of Administrative Hearings (“OAH”) in the above-captioned matter on 5 August

and 6 August 2021, respectively.

2. The Department contends in its Petition that the OAH erred when it

reversed the Department’s assessment of a “large individual income tax deficiency”

penalty against Respondent Greta Ann Clifton (“Clifton” or “Respondent”) under

N.C.G.S. § 105-236(a)(5)(b) for understating her income on her 2015 North Carolina

individual state income tax return by more than 25%. (Petition ¶ 1.)

3. After reviewing the Petition, the related briefing, relevant supporting

materials, and the arguments of counsel and Clifton at the hearing on the Petition,

the Court hereby REVERSES the Final Decision of the OAH for the reasons set forth

below. North Carolina Department of Justice, by Special Deputy Attorney General Ashley Hodges Morgan, for Petitioner North Carolina Department of Revenue.

Greta Ann Clifton, Pro se.

Bledsoe, Chief Judge.

I.

FACTUAL AND PROCEDURAL BACKGROUND

A. Factual Background

4. The Department is an agency of the State of North Carolina responsible for

collecting the State’s tax funds and administering the tax laws set forth in

Subchapter I of Chapter 105 of the North Carolina General Statutes. N.C.G.S. §

143B-218.

5. Respondent was a citizen and resident of North Carolina at all relevant

times in 2015. She was also one of three members of a limited liability company

called GD&T Enterprises, LLC (“GD&T”) and an employee of Acme Plumbing.

(Record on Appeal 879 [hereinafter “R.”], ECF Nos. 19–26, 28.)

6. Respondent timely filed her 2015 North Carolina individual income tax

return (“Tax Return”) along with a federal Schedule C, “Profit or Loss from

Business”—a form allowing individuals to claim deductions from proprietorships. (R.

879.) On her Schedule C, Respondent claimed business income and deductions for

GD&T. (R. 879.)

7. On 21 December 2018, the Department’s Examinations Division, which

conducts initial tax audits, informed Respondent that her Tax Return was being

audited. (R. 201.) The Department submitted an information document request to Clifton requesting that she provide documentation to support her claimed business

expense deductions. (R. 203–04.) As a result of the audit, the Department disallowed

the entire amount of business loss and business expenses that Respondent claimed

on Schedule C of her 2015 federal income tax return and adjusted Respondent’s

federal adjusted gross income from $14,426 to $40,232, an increase of $25,806, or

roughly 64%. (R. 51, 210.) On 25 March 2019, the Department proposed a tax

assessment against Respondent consisting of $1,484 in additional North Carolina

individual income tax, a $371 large individual income tax deficiency penalty under

section 105-236(a)(5)(b) for understating her income by 25% or more, and $230.74 in

interest (collectively, the “Proposed Assessment”). (R. 881.)

8. Respondent timely requested that the Department review the Proposed

Assessment. (R. 881.) During the Department’s review, the Personal Taxes Division

sent Respondent’s case back to the Examination Division to request documentation

so the Department could substantiate Respondent’s claimed deductions. (R. 882.)

Respondent refused the Division’s subsequent request, “writing that she was not

providing any more documentation[.]” (R. 882.) Following its review, the Department

issued a Notice of Final Determination (“Final Determination”) on 30 March 2020

that affirmed the Proposed Assessment and increased the interest owed to account

for the passage of time since the Proposed Assessment was issued. (R. 884, 49.)

B. Procedural Background

9. On 4 May 2020, Respondent timely filed a Petition for a Contested Case

Hearing with the OAH, Case No. 20 Rev 01932, requesting that the OAH review the Department’s Final Determination. (R. 7–18.) OAH Administrative Law Judge

Michael C. Byrne heard Respondent’s petition on 11 May 2021. (R. 878.)

10. Following the hearing, the OAH issued a Final Decision on 5 August 2021

upholding the Department’s denial of Respondent’s claimed business expense

deductions but reversing the Department’s assessment of a large individual income

tax deficiency penalty against Respondent. (R. 887–891.) On 6 August 2021, the

OAH issued an Amended Final Decision, revising two Conclusions of Law regarding

the penalty. (R. 894.)

11. Primarily at issue here is the OAH’s amended conclusion stating:

[A]n improper deduction and an insufficiently documented deduction, otherwise proper under the evidence submitted, are two different things. At no time did [the Department], by clear and convincing evidence or otherwise, prove that the deductions themselves were improper. The purpose of the statute appears to be penalizing improper deductions, not otherwise proper deductions that fail to meet [the Department’s] somewhat subjective standards of being “sufficiently” documented. Given the subjectivity of [the Department’s] “insufficient documentation” findings under the evidence presented, the Tribunal cannot conclude that [the Department] met its “clear and convincing” burden to demonstrate that [Respondent] “understated” her taxable income as opposed to merely failing to support, again under a subjective standard of determination, an otherwise lawful deduction.

(R. 894 ¶ 21 (emphasis added, bold in original).)

12. Relying on this conclusion, the OAH further concluded:

Thus, while [Respondent]’s negligence is not a factor in determining whether this penalty should be applied, [the Department] did not meet its burden to show by clear and convincing evidence that [Respondent]’s attempted deductions were improper as opposed to merely insufficiently documented. At no time did Respondent demonstrate that Petitioner did anything other than claim deductions and then, when audited, failed (and refused) to present sufficient documentation to support them. Accordingly, the large tax deficiency or “negligence” penalty against Petitioner must be reversed.

(R. 889–90 ¶ 22 (emphasis added).) 1

13. On 7 September 2021, the Department timely filed its Petition pursuant to

N.C.G.S. §§ 150B-43, -45, and -46 in Wake County Superior Court seeking judicial

review of the OAH’s Final Decision. 2 (R. 898.)

14. This action was designated as a mandatory complex business case by order

of the Chief Justice of the Supreme Court of North Carolina dated 16 September 2021,

and the case was assigned to the undersigned the following day. (Designation Order,

ECF No. 1.)

1 Most of Petitioner’s challenges to the OAH’s Final Decision are embraced within Petitioner’s

challenges to the OAH’s amended conclusion of law no. 21 and conclusion of law no. 22. Those challenges include Petitioner’s exceptions to finding of fact no.

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