Nestle R&D Center, Inc. v. Levin

2009 Ohio 1929, 907 N.E.2d 714, 122 Ohio St. 3d 22
CourtOhio Supreme Court
DecidedApril 30, 2009
Docket2008-1285
StatusPublished
Cited by8 cases

This text of 2009 Ohio 1929 (Nestle R&D Center, Inc. v. Levin) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nestle R&D Center, Inc. v. Levin, 2009 Ohio 1929, 907 N.E.2d 714, 122 Ohio St. 3d 22 (Ohio 2009).

Opinion

Per Curiam.

{¶ 1} This case presents a statute-of-limitations question. When a corporate franchise taxpayer claims a tax credit for creating new jobs in Ohio, it does so by filing a refund claim under R.C. 5733.12(B). This case asks when the three-year limitations period for filing such a claim begins to run. The Tax Commissioner and the Board of Tax Appeals (“BTA”) held that the limitations period began to run at the time taxes were deemed to have been paid. Nestle argues that the period began to run at a later time: the date on which the Department of Development issued the certificate that verifies the amount of the tax credit.

{¶ 2} We hold that the three-year limitations period commences to run when the Department of Development issues the certificate. We therefore reverse the BTA’s decision and remand for further proceedings.

*23 I. Facts

A. Procedural history

{¶ 3} Appellant Nestle R&D Center, Inc. (“Nestle”) initiated the present proceedings by filing an application for a refund of corporation franchise tax for tax year 2001. The substantive basis for the claim lies in the refundable credit for Ohio job creation provided by R.C. 122.17 and 5733.0610. The Ohio Tax Credit Authority entered into a ten-year agreement to grant that tax break to Nestle in 1994, and the authority issued a certificate on December 6, 2004, that confirmed the amount of credit that Nestle could claim for tax year 2001. Nestle then filed its refund application on January 6, 2005.

{¶ 4} The Tax Commissioner found that Nestle had filed its application after the three-year limitations period provided by R.C. 5733.12(B) had expired. Having determined that the application was untimely, the commissioner concluded that he lacked jurisdiction to consider it. On appeal, the Board of Tax Appeals (“BTA”) affirmed.

{¶ 5} Before this court, Nestle renews its contention that the three-year statute of limitations set forth in R.C. 5733.12(B) does not bar its refund claim. Nestle argues that the limitations period did not begin to run until it received the certificate allowing the job credit for tax year 2001, which did not occur until December 6, 2004.

B. The job-creation tax credit

{¶ 6} Enacted in 1992, Sub.S.B. No. 363 provided tax breaks designed to encourage job creation by businesses in Ohio. 144 Ohio Laws, Part II, 2642. The act originally provided a credit against the corporation franchise tax and the personal income tax. The enabling provisions are codified at R.C. 122.17.

{¶ 7} The credit becomes available through a formal agreement between the taxpayer and the Ohio Tax Credit Authority, a panel chaired by the Director of Development that consists of four other members selected by the governor and legislative leaders. R.C. 122.17(C), (D), and (M). The basis for computing the credit lies in the amount of income-tax withholding associated with employees who hold the newly created jobs, and the taxpayer negotiates the percentage of withholding to be used in computing the credit as one term of the tax-credit agreement. R.C. 122.17(A)(3) and (D)(4).

{¶ 8} It is significant that the job-creation tax credit is refundable in nature. R. C. 122.17(B); 5733.0610(A). That means that the taxpayer receives the full benefit of the credit even if it does not have sufficient liability to offset in a given tax year. See Sorenson v. Secy. of the Treasury (1986), 475 U.S. 851, 854, 106 S. Ct. 1600, 89 L.Ed.2d 855 (unlike other credits that can be used “only to offset tax that would otherwise be owed,” the federal earned-income credit is refunda *24 ble, meaning that if an individual’s earned-income credit exceeds his tax liability, the excess amount is considered an overpayment of tax to be refunded to the taxpayer); R.C. 5733.0610(A) (“taxes equal to the amount of the refundable credit shall be considered to be paid to this state on the first day of the tax year”); cf. R.C. 5733.98(A)(31) and 5733.98(B) (distinguishing refundable credits such as the job-creation credit from those for which “the amount of the credit for a tax year shall not exceed the tax due after allowing for any other credit that precedes it in the order required under this section”). Thus, when the amount of the job-creation tax credit exceeds the tax liability as to a particular year, the state first applies the excess against other debts the taxpayer owes to the state, and then disburses any remaining excess to the taxpayer as a refund payment. R.C. 5733.121.

C. The grounds for dismissal by the Tax Commissioner and the BTA

{¶ 9} The record is not extensively developed in this case, but it does contain four Ohio Tax Credit Authority certificates that pertain to taxable years 2000 through 2003. Each of the certificates refers to the underlying agreement between Nestle and the authority: the agreement was entered into on April 20, 2004, and extended from January 1995 to December 2004. For each year in the record, the certificate allowed a credit in the amount of 60 percent of the income-tax withholding attributable to newly created jobs during the taxable year. 1

{¶ 10} R.C. 5733.12(B) states that an application for a refund of franchise tax shall be filed “within three years from the date of the illegal, erroneous, or excessive payment of the tax.” The statute further clarifies that a payment made before the franchise tax return was due “shall be deemed to have been made on the due date or extended due date.” The Tax Commissioner applied R.C. 5733.12(B) to Nestle’s refund claim and found that the claim was untimely.

{¶ 11} The commissioner predicated his dismissal on the timing of the “payment” under R.C. 5733.12(B). For taxable year 2000, Nestle obtained an extension for its federal income tax return to September 17, 2001, which automatically extended Nestle’s Ohio franchise-tax filing deadline for tax year 2001 to October 15, 2001. See R.C. 5733.13 (Ohio extended due date falls on the 15th day of the month following the federal extended due date). Since Nestle’s payments for tax year 2001 consisted either of previously tendered estimated payments or carry-forward from a previous year, the commissioner determined *25 that the three-year limitations period commenced on October 15, 2001. The commissioner focused on that date because, pursuant to R.C. 5733.12(B), that date was the extended due date to which those earlier payments related. As a result, the commissioner concluded that the deadline for Nestle to claim a refund for tax year 2001 fell on October 15, 2004. Under the commissioner’s reading of the statute, the filing of a refund claim after that date would be time-barred.

{¶ 12} On December 6, 2004, the Department of Development issued the certificate verifying the amount of credit for the 2000 taxable year, i.e., for franchise tax year 2001. That agency computed the 2001 credit to be $43,696.80, which is 60 percent of the new-employee withholding. Nestle thereafter filed its application for refund on January 6, 2005, asking for a refund in the amount of $43,697.

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Bluebook (online)
2009 Ohio 1929, 907 N.E.2d 714, 122 Ohio St. 3d 22, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nestle-rd-center-inc-v-levin-ohio-2009.