Nelnet, Inc. v. State Tax Assessor

CourtSuperior Court of Maine
DecidedDecember 8, 2008
DocketKENap-07-24
StatusUnpublished

This text of Nelnet, Inc. v. State Tax Assessor (Nelnet, Inc. v. State Tax Assessor) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nelnet, Inc. v. State Tax Assessor, (Me. Super. Ct. 2008).

Opinion

STATE OF MAINE SUPERIOR COURT CIVIL ACTION KENNEBEC, ss. DOCKET NO. AP-97-24 J!\II '--- ~i,::;"J\_- I~ e;t... , ) '._ ' ' \ "l iC" /-'. ",J - : ••

NELNET, INC., et al.,

Petitioners

v. DECISION AND ORDER

STATE TAX ASSESSOR

Respondent

Before the court are cross-motions for summary judgment! on petitioners' M.R.

Civ. P. SOC petition for judicial review challenging an assessment of corporate income

tax by the State Tax Assessor (Assessor). For the following reasons, the petitioners'

motion is granted.

FACTS

1. Petitioners' Business Structure

Nelnet, Inc. is a Nebraska corporation. (PSMF en: 1; RRSMF en: 1.) During 2002,

2003 and 2004 (the "Contested Tax Years"), Nelnet and its subsidiaries (together,

"petitioners") operated as a unitary business doing business in almost all 50 states,

including Maine. (PSMF en: 2; RRSMF en: 2.) Generally, petitioners business was

originating, acquiring, holding, servicing and guaranteeing student loans. (PSMF en: 3;

RRSMF en: 3.)

I Petitioners filed their motion on April 22, 2008. The State Tax Assessor (the Assessor) filed his motion on April 23, 2008. Additionally, the Assessor filed a Motion to Exclude expert testimony on April 23, 2008. 2

During the Contested Tax Years, petitioners' unitary business consisted of

approximately 25-35 entities. 2 (PSMF 9[ 4; RRSMF

as "special purpose corporations" (SPCs), formed to protect their assets from

bankruptcy and hold beneficial interests in trust indentures used to fund student loans.

(PSMF 9[ 5-6; RRSMF 9[ 5-6.) The SPCs were separate legal entities, had their own tax

identification numbers, held beneficial interests in the student loans, had no employees,

and were incorporated primarily in Nevada, Nebraska or Delaware. (PSMF 9[

RRSMF

II. The Loan Process

As part of its Maine loan business, Nelnet established itself as a preferred lender,

which Maine residents attending schools inside and outside of Maine could select.

(PSMF

application, the u.s. Department of Education provided financial eligibility information

to a student's school. (RRSMF

attended by Maine borrowers sent award letters to students. (PSMF ~ 37, RRSMF

After receiving an award letter, the student completed the standard promissory note

and selected a lender. If a student selected Nelnet as the lender, the SPCs would hold

the legal title to the promissory note and the student/borrower would be obligated to

repay the SPCs. (PSMF ~

for the requested financial aid, the school would direct Nelnet to forward the loan funds

to the school for disbursement to the student's account. (PSMF <]I 43; RRSMF <]I 43.) The

SPCs also acquired student loans from lenders to whom other Nelnet entities provided

2 Each entity was assigned separate tax identification numbers, except for entities organized as limited

liability companies that were 100% owned by the parent company, Nelnet. (PSMF 'J[ 4; RRSMF 'J[ 4.) 3

marketing and/ or origination services, and/ or from lenders who had agreed to sell

loans to the SPCs. (RRSMF

III. Petitioners' Maine Loan Activities

Petitioners have maintained an office in Portland since 2001, staffed during the

Contested Tax Years by employees of Nelnet Marketing Solutions, Inc., Nelnet Loan

Services, Inc., Nelnet, Inc., and Nelnet Corporation. (PSMF

During the Contested Tax Years, between 6 and 14 employees worked in the Maine

office. (PSMF

loans to Maine residents for post-secondary education in schools both within and

outside of Maine. (RRSMF

administered parts of the loan origination process, including marketing and solicitation

activities and data entry in connection with student loans that petitioners funded and

disbursed to Maine colleges and universities. (PSNIF

of 2004, these activities were relocated from the Maine office to other offices throughout

the country. (PSMF

peti tioners' student loan business were performed in offices located outside of Maine.

(PSMF

During the Contested Tax Years, certain SPCs received interest and servicing fees

from loans to Maine residents ("Maine Student Loan Income"). (PSNIF

not all Maine residents receiving student loans attended colleges or universities in

Maine, these loans were disbursed to schools both within and outside of Maine. (PSMF

9I 22.) Certain SPCs also received interest and servicing fees generated by student loans that were acquired by the SPCs, but were originally funded and disbursed by other

lending intuitions. (PSMF 9I 22.) 4

During 2003 and 2004, National Education Loan Network (NELN), a separate

legal entity with its own tax identification number, received interest generated by

student loans funded and disbursed to Maine residents attending colleges or

universities both within and outside of Maine, by NELN or other lending institutions,

whose loans NELN subsequently acquired. (PSMF

had a line of credit so that it could fund loans for a temporary 30-90 day period until the

loan could be fully funded. (PSMF

student loans initially funded and temporarily held by NELN were ultimately

transferred to an Spc. (PSMF

In 2004 Nelnet, Inc. received servicing fees generated by loans funded and

disbursed to schools attended by Maine residents both within and outside of Maine.

(PSMF

Nelnet's unitary business receiving interest and servicing fees related to student loans

to Maine residents attending schools both within and outside of Maine in 2002, 2003,

and 2004, were SPCs. (PSMF

Petitioners filed a single Maine combined corporate income tax return for 2001,

and each of the Contested Tax Years, listing each taxpayer entity in its Combined

Report, including the SPC that received interest and servicing fees. (PSMF

petitioners contend was erroneous and for which they could have demanded a refund.

(PSMF

sales. (PSMF

IV. The Assessment

On May 18, 2006, the MRS issued an Assessment of Income Tax, Interest and

Penalties for $600,428.96, based upon Nelnet's failure to include Maine Student Loan 5

Income in the Maine sales factor numerator during the Contested Tax Years. On

January 29,2007, on reconsideration, the Assessor upheld the assessment based on its

determination that interest and servicing fees received by SPCs during the Contested

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