Newell Normand, Sheriff and Ex-Officio Tax Collector for the Parish of Jefferson Versus Mr. Mudbug, Inc. and Michael J. Maenza

CourtLouisiana Court of Appeal
DecidedDecember 30, 2019
Docket19-CA-272
StatusUnknown

This text of Newell Normand, Sheriff and Ex-Officio Tax Collector for the Parish of Jefferson Versus Mr. Mudbug, Inc. and Michael J. Maenza (Newell Normand, Sheriff and Ex-Officio Tax Collector for the Parish of Jefferson Versus Mr. Mudbug, Inc. and Michael J. Maenza) 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
Newell Normand, Sheriff and Ex-Officio Tax Collector for the Parish of Jefferson Versus Mr. Mudbug, Inc. and Michael J. Maenza, (La. Ct. App. 2019).

Opinion

NEWELL NORMAND, SHERIFF AND NO. 19-CA-272 EX-OFFICIO TAX COLLECTOR FOR THE PARISH OF JEFFERSON FIFTH CIRCUIT

VERSUS COURT OF APPEAL

MR. MUDBUG, INC. AND STATE OF LOUISIANA MICHAEL J. MAENZA

ON APPEAL FROM THE TWENTY-FOURTH JUDICIAL DISTRICT COURT PARISH OF JEFFERSON, STATE OF LOUISIANA NO. 742-546, DIVISION "C" HONORABLE JUNE B. DARENSBURG, JUDGE PRESIDING

December 30, 2019

JUDE G. GRAVOIS JUDGE

Panel composed of Judges Fredericka Homberg Wicker, Jude G. Gravois, and Robert A. Chaisson

JUDGMENT VACATED; MATTER REMANDED JGG FHW RAC COUNSEL FOR PLAINTIFF/APPELLEE, JOSEPH P. LOPINTO, III, SHERIFF AND EX-OFFICIO TAX COLLECTOR FOR THE PARISH OF JEFFERSON, SUCCESSOR IN OFFICE TO FORMER JEFFERSON PARISH SHERIFF NEWELL NORMAND Kenneth C. Fonte

COUNSEL FOR DEFENDANT/APPELLANT, MR. MUDBUG, INC. Charles V. Cusimano, III Michael G. Gaffney Christopher M. Gaffney GRAVOIS, J.

Appellant, Mr. Mudbug, Inc. (“Mr. Mudbug”), a business operating in

Jefferson Parish, appeals a January 28, 2019 trial court judgment in favor of

Newell Normand, Sheriff and Ex-Officio Tax Collector for the Parish of Jefferson

(“Collector”), finding Mr. Mudbug liable to the Collector for use taxes for the tax

periods January 2007 through June 2009.1 On appeal, Mr. Mudbug argues that the

trial court erred in ruling that Mr. Mudbug was precluded from asserting any

defenses to the Collector’s Rule for Taxes at the trial on the merits of the matter.

Mr. Mudbug asks that the judgment under review be reversed and the matter be

remanded for a trial on the merits of the matter wherein it may assert its affirmative

defenses to the Collector’s Rule for Taxes.

For the following reasons, after benefit of review of the full appellate record

and a previous writ application filed with this Court, we find merit to Mr.

Mudbug’s arguments on appeal. Accordingly, the trial court’s January 28, 2019

judgment is hereby vacated and the matter is remanded to the trial court for further

proceedings consistent with this opinion.

PROCEDURAL HISTORY

On June 16, 2014, the Collector sent Mr. Mudbug a Notice of Delinquent

Taxes and Civil Enforcement. On June 26, 2014, Mr. Mudbug responded to the

Notice, claiming that the taxes in question had prescribed. On September 17,

2014, the Collector filed in the Twenty-fourth Judicial District Court a Rule for

Taxes, a summary proceeding, against Mr. Mudbug and Michael J. Maenza,2 as

authorized by La. R.S. 47:337.61. Therein, the Collector alleged that Mr. Mudbug

1 At the time the Rule for Taxes was filed in the district court, Newell Normand was Sheriff and Ex-Officio Tax Collector for the Parish of Jefferson. He has since been succeeded by Joseph P. Lopinto, III, but it does not appear that the suit was amended to reflect this. 2 All claims against Mr. Maenza, principal of Mr. Mudbug, were dismissed with prejudice by the trial court’s October 26, 2016 judgment. Accordingly, remaining references in this opinion to “taxpayer” will refer solely to Mr. Mudbug.

19-CA-272 1 had failed to remit use taxes during the monthly tax periods from January 2006

through June 2009, inclusive. The Rule additionally claimed that Mr. Mudbug was

liable to the Collector for statutory interest, penalties, attorney’s fees, and costs.

The petition attached a two-page “Case Summary” showing a total balance due of

$99,289.79, as well as an affidavit from the Collector’s Office as required by La.

R.S. 47:337.61.

As per the requirements of La. R.S. 47:337.61(2), Mr. Mudbug filed

Exceptions of Vagueness and Prescription and Answer/Opposition to Rule with

Affirmative Defenses, detailing ten affirmative defenses to the Rule.3 The

exception of prescription argued that the taxes sought had all prescribed under the

three-year prescriptive periods of La. Const. art. VII, § 16 and La. R.S. 33:2718.4,

again claiming that the taxpayers “have not heard from the Parish on this matter in

almost 4 years.”

The events of “almost 4 years” ago referred to by Mr. Mudbug in its Answer

began when the Collector sent Mr. Mudbug a proposed use tax assessment on

September 22, 2010. On October 11, 2010, Mr. Mudbug protested the proposed

assessment and requested a hearing before the Collector. According to the

pleadings, a hearing on the protest was held on October 28, 2010. On October 29,

2010, a Notice of Delinquent Taxes – Formal Assessment was issued to Mr.

Mudbug by the Collector under La. R.S. 47:337.51, which was delivered to Mr.

Mudbug on November 1, 2010. The Notice of Delinquent Taxes – Formal

Assessment, which complied with statutory requirements in effect at the time,

informed Mr. Mudbug that it had three options, one of which must be exercised

within 60 calendar days: pay the assessment in full, request a hearing with the

3 The exception of vagueness asserted that the Rule failed to state any factual basis for the alleged balance of use taxes due, that the Rule made no reference to any proposed assessment, notice of assessment, or audit, and that the amounts claimed in the Rule are not consistent with “discussions four years ago” for either the sales taxes or use taxes.

19-CA-272 2 Collector, or pay the assessment under protest in accordance with La. R.S.

47:337.63. The record indicates that the parties were in contact in November of

2010 several times, conducting further business regarding the formal assessment. 4

On December 28, 2010, Mr. Mudbug hand delivered its request for a

hearing, as per the October 29, 2019 notice of formal assessment, to the Collector.

The Collector’s records contain a letter to Mr. Mudbug’s counsel dated January 4,

2011, stating that it found Mr. Mudbug’s request for a hearing untimely, but that it

would schedule a meeting between the parties on January 26, 2011. However, Mr.

Mudbug has since maintained, in both its correspondence to the Collector after

receiving the Notice of Delinquent Taxes in June of 2014, and after being served

with the Rule for Taxes in September of 2014, and in its answer and exceptions to

the Rule for Taxes, that it had not received any further communication from the

Collector after it hand delivered its request for a hearing on December 28, 2010.5

Both Ms. Jeannine Theriot’s testimony at a later hearing on the exception of

prescription and the Collector’s records confirm that Mr. Mudbug did not appear

for the January 26, 2011 meeting offered in the January 4, 2011 letter, nor did Mr.

Mudbug contact the Collector’s Office in any way regarding the proposed meeting,

despite earlier regular correspondence between the parties from the date of the

proposed assessment (September 22, 2010). The record as a whole indicates that

there was no further contact between the parties until June of 2014, “almost 4

years” later, when Mr. Mudbug received the Collector’s Notice of Delinquent

4 For example, in November of 2010, Mr. Mudbug sent the Collector a request for arbitration pursuant to La. R.S. 47:337.51 that Mr. Mudbug later acknowledged was without effect because it was not entitled to arbitration under the version of that statute in effect at that time. 5 The record shows that for other correspondence and notices sent by the Collector to Mr. Mudbug, the Collector’s records contained the “green card” evidencing the certified mail receipt by Mr. Mudbug.

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Newell Normand, Sheriff and Ex-Officio Tax Collector for the Parish of Jefferson Versus Mr. Mudbug, Inc. and Michael J. Maenza, Counsel Stack Legal Research, https://law.counselstack.com/opinion/newell-normand-sheriff-and-ex-officio-tax-collector-for-the-parish-of-lactapp-2019.