OSBA v. Dept. of Rev.

22 Or. Tax 281
CourtOregon Tax Court
DecidedOctober 7, 2016
DocketTC 5262
StatusPublished

This text of 22 Or. Tax 281 (OSBA v. Dept. of Rev.) is published on Counsel Stack Legal Research, covering Oregon Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
OSBA v. Dept. of Rev., 22 Or. Tax 281 (Or. Super. Ct. 2016).

Opinion

No. 29 October 7, 2016 281

IN THE OREGON TAX COURT REGULAR DIVISION

OREGON SCHOOL BOARDS ASSOCIATION, Plaintiff, v. DEPARTMENT OF REVENUE, and Marion County Assessor, Defendants. (TC 5262) Plaintiff (taxpayer) appealed from a Magistrate Division decision as to exemption status of real property it owns in Salem, Oregon. The property at issue was used as a parking lot for taxpayer’s members that visit Salem for business and other purposes. Defendant Marion County Assessor (the county) initially denied taxpayer’s application for exemption on the grounds that taxpayer was not a school district, a public or municipal corporation, or organized as a corpora- tion, but during litigation, the county did not continue to maintain that taxpayer did not qualify as a “corporation” under ORS 307.090, and neither the county nor Defendant Department of Revenue (the department) disputed that tax- payer’s property was being used for taxpayer’s corporate purposes. The depart- ment instead argued that taxpayer did not qualify as a public corporation because it was not created or authorized by statute and did not possess governmental powers or responsibilities. The county argued that taxpayer did not qualify as a public corporation because it only served its members, which are not citizens. Taxpayer argued that it qualified as a public corporation because it advances public education in Oregon through assistance to its membership, which is com- posed entirely of other public corporations. Granting taxpayer’s motion and deny- ing the department and county’s cross-motions, the court ruled that because it served a public purpose, was exclusively managed and controlled by public enti- ties, was impliedly authorized by statute, and was created by public entities with the limited power and authority necessary to accomplish its purpose, taxpayer was entitled to an exemption for the subject property.

Oral argument on cross-motions for summary judgment was held March 21, 2016, in the courtroom of the Oregon Tax Court, Salem. James E. Mountain, Jr., Harrang Long Gary Rudnick PC, Portland, filed the motion and argued the cause for Plaintiff (taxpayer). Scott A. Norris, Assistant Marion County Counsel, Salem, filed the cross-motion and argued the cause for Defendant Marion County Assessor (the county). Daniel Paul, Assistant Attorney General, Department of Justice, Salem, filed the cross-motion and argued 282 OSBA v. Dept. of Rev.

the cause for Defendant Department of Revenue (the department). Decision for Plaintiff rendered October 7, 2016. HENRY C. BREITHAUPT, Judge. I. INTRODUCTION This case is before the court on cross-motions for summary judgment. Plaintiff Oregon School Boards Association (OSBA or taxpayer) appeals from a Magistrate Division decision. The magistrate upheld a denial by Defendant Marion County Assessor (the county) of taxpayer’s application for property tax exemption for tax year 2014-15 for “corporate property used or intended for corporate pur- poses of * * * [a] public * * * corporation[ ] in this state.” See ORS 307.090(1).1 The county and Defendant Department of Revenue (the department) have argued separate bases for denying taxpayer an exemption under ORS 307.090(1). II. FACTS Taxpayer is a voluntary, unincorporated association of 196 public K-12 school districts, 17 public community col- leges, 19 public education service districts, 87 public charter schools, and the State Board of Education. All public school boards in Oregon are eligible for automatic membership in OSBA upon the payment of dues. The purpose of taxpayer is to advance public education in Oregon through services and assistance to its public members.2 1 Unless otherwise noted, the court’s references to the Oregon Revised Statutes (ORS) are to the 2013 edition. 2 Taxpayer’s specific purposes are listed in its constitution, and are: (1) to work for the general advancement and improvement of the education of all youth of the State of Oregon; (2) to gather and disseminate information pertinent to the successful operation of public schools; (3) to work for the most efficient and effective organization of public schools of this state—public schools include local school districts, education service districts and community colleges; (4) to work for adequate and dependable financial support for the public schools of this state; (5) to study all legislation which affects the public schools of Oregon and to support and work for that which appears to be desirable and to keep members informed thereof to propose and work for the enactment of proper education legis- lation; (6) to cooperate and work with persons and organizations genuinely inter- ested in public education; (7) to encourage the establishment and maintenance of high standards in the conduct and operation of the educational endeavor; (8) to study and interpret educational programs and to relate them to the needs of Cite as 22 OTR 281 (2016) 283

Taxpayer is led by a board of directors. Taxpayer can buy and sell property, enter into contracts, and sue and be sued in its own name. Taxpayer is funded by member- ship dues. These funds can only be used to further the pub- lic purposes of taxpayer and must, upon dissolution of tax- payer, be distributed to one or more of its public members. Taxpayer has been the subject of various administrative rulings regarding its public character.3 The real property at issue is located in Marion County. It is used as a parking lot for OSBA members that visit Salem for educational purposes, meetings, lobbying the legislature, and other purposes. It is owned solely by tax- payer, and not by taxpayer’s members. The county denied taxpayer’s application for exemption because OSBA is not (1) a school district; (2) a “public or municipal corporation;” or (3) organized as a corporation. III. ISSUES The court first notes what is not at issue. Taxpayer does not argue that it is a school district. The county no longer maintains that taxpayer does not qualify as a “cor- poration” under ORS 307.090(1). See Pacific States Marine Fisheries v. Dept. of Rev. (Pacific States), 346 Or 117, 122-24, 206 P3d 1037 (2009) (holding formal organization as a cor- poration is not required under ORS 307.090). Further, nei- ther the county nor the department dispute that taxpayer’s property is being used for taxpayer’s corporate purposes.

pupils; (9) to promote public understanding of the role of school boards and school board members in the improvement of education; (10) to conduct, independently or in cooperation with others, seminars, conferences, courses, and research proj- ects in the various aspects of education; (11) to endeavor to implement the pol- icies, beliefs, and resolutions of the association; (12) to do such other things as the member boards or board of directors may deem appropriate for the accom- plishment of these and other purposes which tend to improve education; (13) to provide such direct services to member districts and their board members as may be appropriate and authorized by the board of directors of the association; and (14) to enter into such cooperative agreement with member districts for the pool- ing of resources as may result in the more efficient utilization of district resources and accrue to their financial advantage. (See Stip Facts at 2-3.) 3 These rulings, however, do not dictate the outcome in this case.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Gaines
206 P.3d 1042 (Oregon Supreme Court, 2009)
Shasta View Irrigation District v. Amoco Chemicals Corp.
986 P.2d 536 (Oregon Supreme Court, 1999)
State Ex Rel. Eckles v. Woolley
726 P.2d 918 (Oregon Supreme Court, 1986)
City of Portland v. Multnomah County
296 P. 48 (Oregon Supreme Court, 1931)
Mohler Et Ux. v. Fish Commission
276 P. 691 (Oregon Supreme Court, 1929)
McClain v. Regents of the University
256 P. 412 (Oregon Supreme Court, 1928)
Cook v. Port of Portland
13 L.R.A. 533 (Oregon Supreme Court, 1891)

Cite This Page — Counsel Stack

Bluebook (online)
22 Or. Tax 281, Counsel Stack Legal Research, https://law.counselstack.com/opinion/osba-v-dept-of-rev-ortc-2016.