RREF III-P Fremont Place LLC v. Multnomah County Assessor

CourtOregon Tax Court
DecidedNovember 30, 2023
DocketTC-MD 230356R
StatusUnpublished

This text of RREF III-P Fremont Place LLC v. Multnomah County Assessor (RREF III-P Fremont Place LLC v. Multnomah County Assessor) 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
RREF III-P Fremont Place LLC v. Multnomah County Assessor, (Or. Super. Ct. 2023).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax

RREF III-P FREMONT PLACE LLC, ) ) Plaintiff, ) TC-MD 230356R ) v. ) ) MULTNOMAH COUNTY ASSESSOR, ) ORDER GRANTING DEFENDANT’S ) MOTION FOR PARTIAL SUMMARY Defendant. ) JUDGMENT

This matter is before the court on Defendant’s Motion for Partial Summary Judgment

(Motion), filed September 28, 2023. Plaintiff filed its Complaint on July 19, 2023, appealing an

omitted property assessment notice for tax account number R699148 (subject property), dated

June 15, 2023, for the 2021-22 and 2022-23 tax years.

I. STATEMENT OF FACTS

The facts recited here are based on Plaintiff’s Complaint, Defendant’s Answer, the

Declaration of Veronica Clevidence in Support of Defendant’s Motion for Partial Summary

Judgment (Decl), and Plaintiff’s Response to Defendant’s Motion for Partial Summary

Judgment.

The subject property is an office building located at 1750 Northwest Naito Parkway,

Portland, Oregon 97209. In 2010, Legacy Health (Legacy), as a tenant in the subject property,

applied for, and received, a property tax exemption from Defendant for a percentage of its

occupancy within the building. Legacy’s lease expired in 2015, and a new property tax

exemption was granted based on an updated lease expiring in 2021. On January 19, 2021,

Legacy applied for, and was granted, a property tax exemption under a lease set to expire

November 30, 2022. (Decl at Ex 2.)

ORDER GRANTING DEFENDANT’S MOTION FOR PARTIAL SUMMARY JUDGMENT TC-MD 230356R 1 On December 27, 2022, Defendant mailed Legacy a notice of lease expiration, reminding

the party to file a new exemption and explicitly stating: “If you are no longer leasing this

property or will not be renewing the lease, please notify our office of when this change has or

will occur.” (Decl at Ex 3.) Responding to this communication on April 10, 2023, Suzanne

Taylor, Director of Tax, Payroll & Accounts Payable for Legacy, informed Defendant via email

that its leased space in the subject property had been vacated by March 31, 2021. Taylor

explained that although there was an initial intention to sublease, the pandemic disrupted those

plans, and Legacy fulfilled its surrender obligations by November 20, 2022. (Decl at Ex 4 at 3.)

As a consequence, Defendant determined that the portion of the subject property leased

by Legacy was not being utilized for an exempt use and revoked the exemption for the 2021-22

and 2022-23 tax years. (Decl at 3.)

II. ISSUE

Did the subject property’s tax exemption terminate, pursuant to ORS 307.112,1 when the

tenant vacated the subject property and only continued to maintain a possessory interest?

III. ANALYSIS

A. Standard for Summary Judgment

The standard for summary judgment is provided by Tax Court Rule (TCR) 47 C,2 which

states in pertinent part:

“The court will grant the motion 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 that is 1 The court’s references to the Oregon Revised Statutes (ORS) are to the 2019 edition. 2 TCR 47 is made applicable by Tax Court Rule – Magistrate Division (TCR-MD) 13 B, which provides “[t]the court may apply TCR 47 to motions for summary judgment, to the extent relevant.”

ORDER GRANTING DEFENDANT’S MOTION FOR PARTIAL SUMMARY JUDGMENT TC-MD 230356R 2 the subject of the motion for summary judgment. The adverse party has the burden of producing evidence on any issue raised in the motions as to which the adverse party would have the burden of persuasion at trial.”

The parties dispute whether there are genuine issues of material fact regarding the

eligibility of the subject property for a property tax exemption under ORS 307.112. Defendant

argues that Legacy’s statement of vacating the property is sufficient to demonstrate non-exempt

use, justifying termination of the exemption. Plaintiff contends that, as Legacy maintained

possession and continued lease payments, a factual dispute exists regarding the type of use,

warranting denial of summary judgment.

B. Charitable Property Tax Exemption

ORS 307.130(2) provides that, “property owned or being purchased by art museums,

volunteer fire departments, or incorporated literary, benevolent, charitable and scientific

institutions shall be exempt from taxation.” However, this exemption applies only to the real or

personal property, or a proportion thereof, that is “actually and exclusively occupied or used in

the literary, benevolent, charitable or scientific work carried on by such institutions.” ORS

307.130(2)(a). Under ORS 307.112, which governs leases by an “exempt” entity for property

owned by non-exempt owners, the property must be used for an exempt purpose and the tax

savings must “inure solely to the benefit of the exempt entity.” ORS 307.112(1)(a),(b).

Exemptions are “strictly construed” with taxation as the rule and exemption, the exception.

Erickson v. Dept. of Rev., 17 OTR 324, 328 (2004).

Under ORS 307.162(7), an owner of property exempt from taxation has an obligation to

report changes in the use of the exempt property. The statute mandates that

“[i]f an institution, organization or person owns property that is exempt from taxation under a provision of law listed in subsection (1) of this section and changes the use of the property to a use that would not entitle the property to exemption from taxation, the institution or organization must notify the county

ORDER GRANTING DEFENDANT’S MOTION FOR PARTIAL SUMMARY JUDGMENT TC-MD 230356R 3 assessor of the change to a taxable use within 30 days.”

ORS 307.162(7). While Plaintiff did not timely comply with this statute, its tenant, Legacy,

eventually informed Defendant of the change in the subject property’s use as of March 31, 2021.

ORS 311.410(4) delineates the timing for when a change of exemption status will trigger the

resumption of taxation:

“Real or personal property is taxable for the ensuing tax year if the property is transferred or changed at any time before July 1 of any year from an exempt ownership to a taxable ownership or taxable use.

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Related

Erickson v. Department of Revenue
17 Or. Tax 324 (Oregon Tax Court, 2004)

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RREF III-P Fremont Place LLC v. Multnomah County Assessor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rref-iii-p-fremont-place-llc-v-multnomah-county-assessor-ortc-2023.