Seneca Sustainable Energy, LLC v. Dept. of Rev.

CourtOregon Tax Court
DecidedDecember 9, 2019
DocketTC 5247
StatusUnpublished

This text of Seneca Sustainable Energy, LLC v. Dept. of Rev. (Seneca Sustainable Energy, LLC 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
Seneca Sustainable Energy, LLC v. Dept. of Rev., (Or. Super. Ct. 2019).

Opinion

IN THE OREGON TAX COURT REGULAR DIVISION Property Tax

SENECA SUSTAINABLE ENERGY, LLC, ) ) Plaintiff, ) TC 5247 (Control); TC 5273; TC 5294; v. ) TC 5323; TC 5355 ) DEPARTMENT OF REVENUE, ) State of Oregon, ) ) ORDER GRANTING PLAINTIFF’S Defendant. ) MOTION FOR SUMMARY JUDGMENT

These consolidated valuation cases involve the same property at issue in Seneca

Sustainable Energy, LLC v. Dept. of Rev., 363 Or 782, 429 P3d 360 (2018), aff’g 22 OTR 263

(2016) and 21 OTR 366 (2014) (the “Prior Case”). The Prior Case involved the tax years

2012-13 and 2013-14, while these cases involve the five succeeding tax years. The substantive

legal issue here is whether this court’s judgment in the Prior Case 1 constituted an “order

correcting the real market value of a separate assessment of property” within the meaning of

Oregon’s “adjudicated value” statute, ORS 309.115. 2 Before reaching that issue, the court must

decide whether Defendant’s most recent actions have rendered these cases moot, and if so,

whether the court can and should decide the substantive issue nonetheless. The court holds that

Defendant has made these cases moot by amending its answers to substitute new, reduced values

1 See Seneca Sustainable Energy, LLC v. Dept. of Rev., TC 5193 (Control) Judgment at 2 (Dec 1, 2016) (the “Prior Case Judgment”). 2 The court’s references to the Oregon Revised Statutes (ORS) are to the 2013 edition.

ORDER GRANTING PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT TC 5247 (CONTROL) Page 1 of 16 consistent with ORS 309.115, but the court exercises its discretion to decide the substantive

issue, consistent with ORS 14.175 and in the interest of efficiently resolving these industrial

property cases as the legislature has encouraged courts to do in ORS 305.487. The court

concludes that the judgment in the Prior Case was an “order correcting the real market value of a

separate assessment of property” for purposes of ORS 309.115(1), and the court orders in these

cases that the assessment and tax rolls be corrected to show the real market values pled in

Defendant’s amended answers.

On November 8, 2018, the Oregon Supreme Court issued its opinion in the Prior Case,

affirming this court’s determination of the real market value (“RMV”) of the subject property 3

for tax years 2012-13 and 2013-14. Seneca, 363 Or 782. Without belaboring the facts recited in

the three opinions in the Prior Case, the Subject Property was exempt under the Oregon

Enterprise Zone Act, but the Supreme Court held that this court nevertheless had jurisdiction to

determine the property’s RMV, and the Supreme Court affirmed the RMV that this court

concluded following a trial. Id.

These cases involve the effect, if any, of the outcome of the Prior Case on the property’s

value for the next five tax years in sequence. Although each property tax year generally “stands

3 The subject property in these five cases (the “Subject Property”) comprises tax accounts numbered 5645217, 1851292 and 0348829 maintained by the Lane County Assessor, as well as tax accounts numbered 1857729 and 1857265. (See Complaints Ex 1, Case Nos. 180400G, 170381G, 160396G, 150514R, 140460D.) The Subject Property is an industrial facility that Defendant Department of Revenue, rather than the county assessor, appraises pursuant to ORS 306.126(2). Accounts 5645217, 1851292 and 0348829 were identified in the judgment in cases 5193 (tax year 2012-13) and 5208 (tax year 2013-14) (Prior Case Judgment at 2.) The property in accounts 1857729 and 1857265 is machinery and equipment and makes up less than 10 percent of the total RMV of the subject property. It is unclear from the record whether the property in accounts 1857729 and 1857265 was included as the subject of the Prior Case Judgment—it is conceivable, for example, that the latter two accounts were split off from one or more of the original three accounts. (See Ptf’s Mot Summ J, Ex 10 at 3 (email correspondence between parties’ counsel).) When preparing the form of judgment in these cases, counsel should confer and present a form of judgment that identifies whether accounts 1857729 and 1857265 are included. For convenience, the court refers to the “Subject Property” as including all five accounts.

ORDER GRANTING PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT TC 5247 (CONTROL) Page 2 of 16 on its own” 4 for purposes of determining value, the legislature has created an exception to that

general rule in ORS 309.115. See AKS LLC v. Dept. of Rev., ___OTR ___(Apr 18, 2019) (slip

op at 14-15) (explaining purpose and circumstances leading to enactment of ORS 309.115). If

the court orders an RMV correction, the statute preserves the corrected RMV for the next five

years, although the assessor may increase the RMV for additions to the property, annual value

“trending” and certain other adjustments. ORS 309.115(1) provides:

“If the Department of Revenue, the board of property tax appeals or the tax court or other court enters an order correcting the real market value of a separate assessment of property and there is no further appeal from that order, except as provided under subsection (2) or (3) of this section, the value so entered shall be the real market value entered on the assessment and tax rolls for the five assessment years next following the year for which the order is entered.”

The parties here disagree whether ORS 309.115 applies to the five tax years 5 2014-15 through

2018-19 (the “Subject Years”). Defendant asserts that the statute does not apply to the Subject

Property because it was exempt from tax for the tax years at issue in the Prior Case.

The procedural posture of these cases is relevant. As the litigation in the Prior Case

proceeded, and as the annual December 31 deadline approached to challenge the value for each

following year, Plaintiff filed what it refers to as a “protective” complaint for the same property.

In the last six years, Plaintiff has filed five such protective complaints covering tax years 2014-

15 through 2018-19 (the “Subject Years”). This court held all but the most recent of these five

cases in abeyance during the Supreme Court appeal. The issue now before the court involves

actions that Defendant took to change the assessment and tax rolls for each Subject Year after the

Supreme Court’s November 8, 2018, decision in the Prior Case.

4 ESCO Corp. v. Dept. of Rev., 307 Or 639, 646, 772 P2d 413 (1989). 5 ORS 309.115(1) refers to “assessment years,” which are calendar years.

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