Pixley v. Commissioner of Revenue

CourtMassachusetts Appeals Court
DecidedJune 22, 2023
DocketAC 21-P-805
StatusPublished

This text of Pixley v. Commissioner of Revenue (Pixley v. Commissioner of Revenue) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pixley v. Commissioner of Revenue, (Mass. Ct. App. 2023).

Opinion

NOTICE: All slip opinions and orders are subject to formal revision and are superseded by the advance sheets and bound volumes of the Official Reports. If you find a typographical error or other formal error, please notify the Reporter of Decisions, Supreme Judicial Court, John Adams Courthouse, 1 Pemberton Square, Suite 2500, Boston, MA, 02108-1750; (617) 557- 1030; SJCReporter@sjc.state.ma.us

21-P-805 Appeals Court

MELISSA PIXLEY & others1 vs. COMMISSIONER OF REVENUE.

No. 21-P-805.

Berkshire. October 6, 2022. – June 22, 2023.

Present: Green, C.J., Henry, & Englander, JJ.

Cellular Telephone. Taxation, Sales tax, Commissioner of revenue. Commissioner of Revenue. Declaratory Relief. Practice, Civil, Declaratory proceeding.

Civil action commenced in the Superior Court Department on July 7, 2017.

A motion to dismiss was heard by John A. Agostini, J., and entry of separate and final judgment was ordered by him.

Jeffrey S. Morneau for the taxpayers. Richard S. Weitzel, Assistant Attorney General, for Commissioner of Revenue.

ENGLANDER, J. This case concerns the sales tax that is

collected in a transaction where the consumer purchases a

discounted cell phone, bundled with the consumer's agreement to

1 William Harrington, Jr., and William Hillman. 2

use a carrier's wireless services for a period into the future.

Pursuant to Department of Revenue Directive 11-2, issued in

2011, the sales tax assessed on the cell phone purchased in such

a "bundled transaction" is based upon the higher of the phone's

wholesale cost to the carrier, or the cash price the consumer

actually pays.

The plaintiffs in this purported class action are consumers

who purchased cell phones in such bundled transactions, and they

challenge the directive, and the tax imposed, on the ground

(among others) that the taxes imposed on the cell phone and the

wireless services exceed the authority of the Commissioner of

Revenue (commissioner) under the sales tax statute, G. L.

c. 64H. The thrust of the plaintiffs' argument is that the

directive causes consumers in such bundled transactions to pay a

tax on more than the price they paid for the cell phone and the

services. For his part, the commissioner concedes that a tax is

assessed on more than the consumer pays in money; the

commissioner justifies the tax, however, on the theory that the

cell phone and services contract have a taxable value apart from

the money the consumer actually pays. For the reasons that

follow, we agree that the directive is contrary to the statutory

definition of the price that is subject to sales tax under G. L.

c. 64H, § 1, and that the plaintiffs are entitled to a

declaratory judgment so stating. 3

Background. 1. General Laws c. 64H. Sales taxes in

Massachusetts are governed by G. L. c. 64H. Section 2 of that

chapter mandates a 6.25 percent tax on retail sales of tangible

personal property and services. The tax is based on a vendor's

"gross receipts" from "sales at retail," which the statute

defines as "the total sales price received by a vendor as . . .

consideration." G. L. c. 64H, §§ 1, 2. In turn, the statute

defines "sales price" as "the total amount paid by a purchaser

to a vendor as consideration for a retail sale, valued in money

or otherwise." G. L. c. 64H, § 1. This case concerns an aspect

of how one determines the "sales price" of the property or

services that are subject to tax.

In practice, and as required by the statute, payment of the

sales tax involves the following steps. When a vendor purchases

an item from a wholesaler to resell it to a consumer, the vendor

gives the wholesaler a resale certificate stating that the item

is being purchased for resale, so that the vendor does not have

to pay the sales tax at that time. See G. L. c. 64H, § 8 (a).

At the time of the retail sale, the vendor collects

reimbursement for the sales tax from the consumer and, later,

remits the sales tax to the commissioner. See G. L. c. 64H,

§§ 2, 3. However, if the vendor makes any use of the item

"other than retention, demonstration or display while holding it

for sale in the regular course of business," then the vendor in 4

effect becomes the consumer of the item, and must itself pay the

sales tax, measured by the wholesale cost of the item. G. L.

c. 64H, § 8 (d).

2. 830 Code Mass. Regs. § 64H.1.4. When a vendor uses the

item itself, it is easy enough to treat the vendor as the

consumer for sales tax purposes. Issues naturally arise,

however, when the vendor resells or transfers an item to a

consumer for no consideration, or at a substantial loss or

discount below the wholesale cost, typically as part of a

promotion. In 2000, the Department of Revenue (department)

promulgated 830 Code Mass. Regs. § 64H.1.4 (regulation) to

address the sales tax on promotional items. The regulation

provides that where a vendor sells an item to a retail consumer

at substantially below cost, or for no or nominal consideration,

the item "constitutes a promotional item for sales tax

purposes," "the vendor is considered its consumer," and the

vendor must pay the sales tax based on the wholesale cost of the

item. 830 Code Mass. Regs. § 64H.1.4(1) (2000). The regulation

permits the vendor to "claim a credit for any tax collected from

the retail consumer." Id.

3. Directive 11-2. That brings us to the "bundled"

transactions at issue here, by which consumers purchase cell

phones but also agree to purchase wireless services for a period

into the future. In such transactions, the price the vendor 5

assigns to the sale of the cell phone is often below wholesale

cost, or even free. In 2011, the department issued guidance --

in the form of a directive -- specifically to address the sales

tax on cell phones sold in such bundled transactions. See

Department of Revenue Directive 11-2 (April 27, 2011) (directive

11-2). Directive 11-2 provides that the sales price of a cell

phone sold in a bundled transaction is the higher of either the

cash price paid or the cell phone's wholesale cost, and that the

sales tax must be paid on that amount. The directive also

permits wireless service carriers and independent retailers to

collect from their customers the full amount of the sales tax,

even when the sales tax is based on the wholesale cost of a cell

phone.2 Directive 11-2 is the directive that the plaintiffs

challenge.3

2 Directive 11-2 specifically provides as follows:

"In situations where the wholesale cost of the phone or other device is used for calculating the tax (because it is higher than the amount paid by the customer), the seller may collect and remit tax from the customer on the wholesale cost. Alternatively, the vendor may elect to assume a portion of the tax by collecting tax from the customer only on the lesser amount actually paid by the customer, in which case, the vendor must also remit tax on the difference between that lesser amount and the wholesale cost" (footnote omitted).

3 Previously, pursuant to two other directives, Department of Revenue Directive 93-9 (December 23, 1993) (directive 93-9) and Department of Revenue Directive 94-2 (February 4, 1994) (directive 94-2), the department treated wireless service carriers and independent retailers differently in determining 6

Procedural history.

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Pixley v. Commissioner of Revenue, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pixley-v-commissioner-of-revenue-massappct-2023.