Picker v. Dept. of Rev.

CourtOregon Tax Court
DecidedSeptember 30, 2020
DocketTC-MD 160268
StatusUnpublished

This text of Picker v. Dept. of Rev. (Picker 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
Picker v. Dept. of Rev., (Or. Super. Ct. 2020).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Income Tax

GRANT E. PICKER ) and PATRICIA A. PICKER, ) ) Plaintiffs, ) TC-MD 160268N ) v. ) ) DEPARTMENT OF REVENUE, ) State of Oregon, ) ) ORDER DENYING ) PLAINTIFFS’ MOTION Defendant. ) FOR SUMMARY JUDGMENT

This matter came before the court on Plaintiffs’ motion to dismiss, filed July 2, 2020.

The court construes Plaintiffs’ motion to dismiss as a motion for summary judgment granting

relief in their favor. Defendant filed its opposition on June 29, 2020. 1

A. Background

Plaintiffs challenge Defendant’s Notice of Assessment for the 2013 tax year, dated May

3, 2016. The Notice of Assessment was based upon Defendant’s Notice of Deficiency, dated

March 17, 2016, disallowing Plaintiffs’ business expenses claimed on their Schedules A and C

because Plaintiffs “failed to provide any support” for the expenses. (Compl at 8-9.) On March

31, 2017, Defendant sent Plaintiffs a letter stating that it “[had] a reason to believe that

[Plaintiffs] had been audited by the IRS” for the 2013 tax year and requesting additional

information based on the IRS adjustments. 2 Defendant further stated that it was “willing to

1 The file dates reflect the date that the court received the document. Plaintiffs dated their motion June 18, 2020, though the court did not receive it until July 2, 2020. Defendant’s response was dated June 26, 2020. 2 Specifically, Defendant requested “IRS form 4549, Income Tax Examination Changes, and form 886-A, Explanation of Items.” (Def’s Ltr, Mar 31, 2017.) Plaintiffs produced those forms in response to Defendant’s request but maintained that they were issued in error because they, along with the Notice of Deficiency, were sent by the IRS to the wrong address. (Ptfs’ Resp to Mot to Compel, May 11, 2017.)

ORDER DENYING PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT TC-MD 160268N 1 adjust [Plaintiffs’] 2013 tax deficiency based on the IRS exam.” (Id.) Upon request of the

parties, the court held this matter in abeyance pending the outcome of the IRS audit

reconsideration. (Or of Abey, May 15, 2017.)

In November 2019, the United States Tax Court dismissed Plaintiffs’ federal case for lack

of jurisdiction because the Commissioner of Internal Revenue had failed to mail its notice of

deficiency to Plaintiffs’ last known address, thus the notice was invalid. (Ptfs’ Ltr at 2, Dec 12,

2019.) The court reactivated this case and held a case management conference with the parties

on March 6, 2020. Plaintiffs maintain that Defendant should cancel its Notice of Assessment for

the 2013 tax year based on the cancellation of the federal notice of deficiency. Defendant stated

that it would not cancel its Notice of Assessment for the 2013 tax year because it was based on

Defendant’s independent 3 adjustments to Plaintiffs’ return and because Plaintiffs’ federal appeal

did not reach the merits of the federal adjustments. Defendant requested documentation from

Plaintiffs to support the items adjusted for the 2013 tax year.

B. Plaintiffs’ Motion

Plaintiffs acknowledge the Notice of Assessment issued May 3, 2016, but maintain that it

“expired” on April 30, 2019, based on an extension agreement signed by the parties in October

2018. (Ptfs’ Mot at 1; Reply, Jul 20, 2020.) Plaintiffs attached a copy of the agreement, a form

entitled “Agreement Extending Period of Limitation for Assessment” for the 2013 and 2014 tax

years, setting a “date extension expiration” of April 30, 2019. (Ptfs’ Mot at 2.) Plaintiffs argue

that, because there was no assessment made by that date, their “Return must go back to Correct

as filed as did the IRS dismissal.” (Id. at 1.) Plaintiffs cite ORS 314.410. (Id. at 4-7.)

3 Defendant maintains that it had opened a review of Plaintiffs’ 2013 return independent of the IRS audit and, indeed, was unaware of the IRS audit at the time Defendant issued its Notice of Deficiency.

ORDER DENYING PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT TC-MD 160268N 2 Defendant responds that no notice of assessment was ever issued under the agreement

referenced by Plaintiffs. (Def’s Resp at 1, Jun 29, 2020.) Defendant further maintains that the

Notice of Assessment issued May 3, 2016, was valid and should be upheld. (Id.)

C. Analysis

The issue presented to the court is not precisely defined, but concerns the validity of the

Notice of Assessment, issued May 3, 2016, for the 2013 tax year in light of a subsequent

extension agreement signed by the parties in October 2018. Plaintiffs bear the burden of proof

and must establish their case by a preponderance of the evidence. ORS 305.427. A

“[p]reponderance of the evidence means the greater weight of evidence, the more convincing

evidence.” Feves v. Dept. of Rev., 4 OTR 302, 312 (1971).

In support of their motion, Plaintiffs cite ORS 314.410, which sets forth time limits in

which Defendant may give notice of deficiency. ORS 314.410(1) provides the general rule: “At

any time within three years after the return was filed, the Department of Revenue may give

notice of deficiency as prescribed in ORS 305.265.” 4 The parties did not identify the date that

Plaintiffs filed their 2013 return. Assuming Plaintiffs’ 2013 return was timely filed without any

extensions, it would have been filed at some time after the close of the 2013 calendar year and on

or before April 15, 2014. See ORS 314.385(1)(a) (requiring personal income tax returns to be

filed “on or before the due date of the corresponding federal return for the tax year as prescribed

under the Internal Revenue Code and the regulations adopted pursuant thereto * * *”); IRC §

6072(a) (setting a general deadline of April 15 following the close of the calendar year for

returns made on that basis). Defendant sent its Notice of Deficiency to Plaintiffs on March 17,

2016, well within three years of the earliest date on which Plaintiffs might have filed their 2013

4 The court’s references to the Oregon Revised Statutes (ORS) are to 2015.

ORDER DENYING PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT TC-MD 160268N 3 return. See ORS 314.410(1). The deficiency was assessed on May 3, 2016, well within one year

of the notice of deficiency. ORS 314.410(5); see also ORS 305.265(7). Both the Notice of

Deficiency and the Notice of Assessment appear to be timely under the relevant statutes and

Plaintiffs have not presented any evidence to the contrary.

Plaintiffs argue that the extension agreement they signed with Defendant in October 2018

invalidated the Notice of Assessment. The purpose of the extension agreement is unclear.

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Related

Feves v. Department of Revenue
4 Or. Tax 302 (Oregon Tax Court, 1971)

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Picker v. Dept. of Rev., Counsel Stack Legal Research, https://law.counselstack.com/opinion/picker-v-dept-of-rev-ortc-2020.