Rivera v. Dept. of Rev.

CourtOregon Tax Court
DecidedApril 30, 2020
DocketTC-MD 190363N
StatusUnpublished

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

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Income Tax

JEFFREY JOEL RIVERA ) and LAURA JUNE RIVERA, ) ) Plaintiffs, ) TC-MD 190363N ) v. ) ) ORDER DENYING PLAINTIFFS’ DEPARTMENT OF REVENUE, ) MOTION FOR SUMMARY State of Oregon, ) JUDGMENT and GRANTING ) DEFENDANT’S CROSS MOTION FOR Defendant. ) SUMMARY JUDGMENT

This matter came before the court on the parties’ written briefings. During the case

management conference held January 8, 2020, Defendant agreed with the facts stated in

Plaintiffs’ Complaint except for allegations pertaining to Plaintiffs’ phone call with Defendant’s

employee. The parties submitted written arguments and additional evidence in accordance with

their agreed-upon schedule. This matter is now ready for the court’s determination.

I. STATEMENT OF FACTS

Plaintiffs purchased solar panels from Solar City and received an Oregon Residential

Energy Tax Credit (RETC) totaling $6,000. (Compl, Ex 1 at 1.) Solar City received

“Permission to Operate” from Portland General Electric on February 6, 2015. (Ptfs’ Ltr, Jan 13,

2020.) Plaintiffs made their first payment to Solar City on April 1, 2015. (Ptfs’ Ltr, Jan 28,

2020, Ex 4.1) A representative of the Oregon Department of Energy (DOE) reported that

Plaintiffs’ RETC application was received April 15, 2015, and certified April 21, 2015. (Ptfs’

Ltr, Jan 13, 2020.) Plaintiffs received a postcard from the DOE postmarked April 22, 2015.

1 Plaintiffs provided an invoice from Solar City dated April 13, 2015, including a section listing “Payments Received” under which the only payment listed was dated April 1, 2015.

ORDER DENYING PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT and GRANTING DEFENDANT’S CROSS MOTION FOR SUMMARY JUDGMENT TC-MD 190363N 1 (Compl, Ex 3.) On the postcard, the $6,000 credit was divided into four $1,500 increments

beginning in the 2014 tax year. (See id.)

Plaintiffs first claimed the RETC credit in the amount of $1,500 on their 2015 tax return

and claimed additional amounts in each tax year through 2018. (See Compl, Ex 1 at 1.) In its

Written Objection Determination letter, dated July 24, 2019, Defendant denied the $1,500 credit

claimed in 2018 stating that Plaintiffs had to claim the credit beginning in 2014 and could not

claim it in 2018. (See id. Ex 5.) Plaintiffs had a net income tax liability exceeding $1,500 in

2014. (Def’s Mot Summ J at 1.) Plaintiffs’ time to amend their 2014 return has expired.

(Compl, Ex 5.)

II. ANALYSIS

The issue presented is whether Plaintiffs are allowed a $1,500 RETC for the 2018 tax

year under ORS 316.116 and accompanying administrative rules.

This matter is effectively before the court on cross motions for summary judgment. The

court shall grant summary judgment

“if the pleadings, depositions, affidavits, declarations, and admissions on file show that there is no genuine issue as to any material fact and that the moving party is entitled to prevail as a matter of law. No genuine issue as to a material fact exists if, based upon the record before the court viewed in a manner most favorable to the adverse party, no objectively reasonable juror could return a verdict for the adverse party on the matter.”

Tax Court Rule 47 C. As the party seeking affirmative relief, Plaintiffs bear the burden of proof

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 Revenue, 4

OTR 302, 312 (1971).

///

/// ORDER DENYING PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT and GRANTING DEFENDANT’S CROSS MOTION FOR SUMMARY JUDGMENT TC-MD 190363N 2 A. RETC Allowed Under ORS 316.116, Generally

ORS 316.116 allows a credit against taxes otherwise due “for costs paid or incurred for

construction or installation of each of one or more alternative energy devices in or at a dwelling.”

ORS 316.116(1)(a).2 The total amount of the credit allowed in any one tax year is limited to the

lesser of the taxpayer’s tax liability or $1,500. ORS 316.116(3)(a), (7).

“Unused credit amounts may be carried forward as provided in subsection (8) of this section, but may not be carried forward to a tax year that is more than five tax years following the first tax year for which any credit was allowed with respect to the category two alternative energy device that is the basis for the credit.”

ORS 316.116(3). Subsection (8) states, in turn, that

“Any tax credit otherwise allowable under this section that is not used by the taxpayer in a particular year may be carried forward and offset against the taxpayer’s tax liability for the next succeeding tax year. Any credit remaining unused in the next succeeding tax year may be carried forward and used in the second succeeding tax year, and likewise any credit not used in that second succeeding tax year may be carried forward and used in the third succeeding tax year, and any credit not used in that third succeeding tax year may be carried forward and used in the fourth succeeding tax year, and any credit not used in that fourth succeeding tax year may be carried forward and used in the fifth succeeding tax year, but may not be carried forward for any tax year thereafter.”

ORS 316.116(5) sets forth requirements “to qualify for a credit under this section.” First,

“[t]he alternative energy device must be purchased, constructed, installed and operated in

accordance with ORS 469B.100 to 469B.118 and a certificate issued thereunder.” ORS

316.116(5)(a). Second, the taxpayer must be the owner or contract purchaser of the dwelling, or

the tenant of either, and must use the dwelling as a principal or secondary residence. ORS

316.116(5)(b). Third, “[t]he credit must be claimed for the tax year in which the alternative

2 The court’s references to the Oregon Revised Statutes (ORS) are to 2017. Generally, the 2017 ORS would apply to the 2018 tax year, however, the 2013 ORS applies to devices certified after January 1, 2012, and before September 1, 2015. See Or Laws 2015, Ch 701, § 37(1), (2); Or Laws 2012, ch 45, §§12, 14. The parties referred to the 2017 statutes. No material changes to the relevant statutes occurred between 2013 and 2017.

ORDER DENYING PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT and GRANTING DEFENDANT’S CROSS MOTION FOR SUMMARY JUDGMENT TC-MD 190363N 3 energy device was purchased if the device is operational by April 1 of the next following tax

year.” ORS 316.116(5)(c).

Defendant and the DOE have each promulgated rules implementing the RETC program.

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Related

State v. Gaines
206 P.3d 1042 (Oregon Supreme Court, 2009)
D. R. Johnson Lumber Co. v. Department of Revenue
866 P.2d 1227 (Oregon Supreme Court, 1994)
Portland General Electric Co. v. Bureau of Labor & Industries
859 P.2d 1143 (Oregon Supreme Court, 1993)
Feves v. Department of Revenue
4 Or. Tax 302 (Oregon Tax Court, 1971)
North Harbour Corp. v. Department of Revenue
16 Or. Tax 91 (Oregon Tax Court, 2002)
Keller v. Department of Revenue
12 Or. Tax 381 (Oregon Tax Court, 1993)

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