Spang v. Department of Revenue

16 Or. Tax 166, 1999 Ore. Tax LEXIS 38
CourtOregon Tax Court
DecidedNovember 4, 1999
DocketTC-MD 982156C
StatusPublished
Cited by1 cases

This text of 16 Or. Tax 166 (Spang v. Department of Revenue) 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
Spang v. Department of Revenue, 16 Or. Tax 166, 1999 Ore. Tax LEXIS 38 (Or. Super. Ct. 1999).

Opinion

DAN ROBINSON, Magistrate.

Plaintiff appeals from a Notice of Refund Adjustment issued by Defendant Oregon Department of Revenue (the department) dated March 6,1998. Plaintiff represented herself at trial. The department’s representative was David Zeh, an Auditor with the department. The issue is whether Plaintiff resided within “federally recognized Indian country in Oregon” in 1997 and therefore qualifies for the state income tax exemption provided under ORS 316.777.1

STATEMENT OF FACTS

Plaintiff is an enrolled member of the Siletz Indian Tribe working for the tribe in its Tribal Administration Building in the town of Siletz, Oregon, as the Indian Child Welfare Director. Plaintiff lives in the town of Newport, which is in Lincoln County. Lincoln County is a federally designated service area for the Siletz Indian Tribe. The tribe has land set aside for member housing in Lincoln County, but none in the town of Newport. The land set aside was purchased by the tribe and transferred to the U.S. Secretary of the Interior to be held in trust for tribal members for residential purposes.

The Siletz Indian Tribe had its reservation terminated in 1955 and restored in 1977. The Tribe currently owns 3,987 acres of land in Oregon designated as reservation land. That land is used for the growing and harvesting of timber and no tribal members live on the formal reservation. Plaintiff travels throughout 11 counties in Oregon and elsewhere within and outside of Oregon discharging her duties as Director of Indian Child Welfare Services.

ANALYSIS

Oregon law exempts the income of certain qualifying American Indians from state income tax. The specific statutory grant provides as follows:

[168]*168“(1) Any income derived from sources within the boundaries of federally recognized Indian country in Oregon by any enrolled member of a federally recognized American Indian tribe residing in federally recognized Indian country in Oregon at the time the income is earned is exempt from tax under this chapter.”

ORS 316.777.

Thus, the statute establishes a three-part test for the entitlement to state income tax exemption: (1) a taxpayer must be an enrolled member of a federally recognized American Indian tribe; (2) a taxpayer’s income must be derived from sources within the boundaries of federally recognized Indian country in Oregon; and (3) a taxpayer must reside in federally recognized Indian country.

The primary dispute here is whether Plaintiff resides within federally recognized Indian country, although the department also asserts Plaintiffs income is not derived from sources within the boundaries of federally recognized Indian country. The court need only reach the second issue if Plaintiff prevails on the first, since all three requirements of the statute must be satisfied in order to fall within the statutory exemption from state income taxes.

Under federal law, the term “Indian country’ is comprised of three separate categories: (1) reservation land; (2) dependant Indian communities; and (3) Indian allotments.2 Oregon defines the term Indian country by administrative rule as “any federally recognized Indian reservation or other land that has been set aside for the residence of tribal Indians under federal protection.” OAR 150-316.777(2).

Plaintiff contends that the health services district in which she resides constitutes Indian country. Plaintiff [169]*169argues that many members of her tribe, herself included, do not live on a reservation and that under Public Law 95-195, it is up to Congress, and not the State of Oregon, to define Indian country. Since the income tax exemption is granted by state law, Oregon does have authority to define the terms. Moreover, the court notes that Congress has defined Indian country in 18 USC section 1151 (1994), as set out in footnote two, and the outcome of Plaintiffs appeal will be guided by federal as well as state law.

Since Plaintiff acknowledges that she does not live on a reservation or on an Indian “allotment,”3 Plaintiff must establish that she lives within a “dependent Indian community,” as provided in subsection (b) of 18 USC section 1151, to fall within the federal definition of Indian country. Plaintiff clearly does not live on land set aside for the residence of tribal Indians under federal protection, as required by the state’s administrative rule (OAR 150-316.777(2)), as set out above. Thus, the specific question to be answered is whether the health service district in which Plaintiff resides is a dependent Indian community.

The applicable statute, 18 USC section 1151, defining Indian country was passed by Congress in 1948. The first United States Supreme Court case to interpret the term “dependant Indian community,” as found in 18 USC section 1151(b), was Alaska v. Native Village of Venetie Tribal Government et al., 522 US 520, 118 S Ct 948, 140 L Ed 2d 30 (1998). In that decision, the court held that the term “depend-ant Indian communities” refers:

“* * * to a limited category of Indian lands that are neither reservations nor allotments, and that satisfy two requirements — first, they must have been set aside by the Federal Government for the use of the Indians as Indian land; second, they must be under federal superintendence. Our holding is based on our conclusion that in enacting § [170]*1701151, Congress codified these two requirements, which previously we had held necessary for a finding of ‘Indian country generally.”

Venetie, 522 US at 527.

The Court was clear in Venetie that there must be both a “federal set-aside” and a “federal superintendence” for a finding of dependent Indian community. Id.

A Health Service Delivery Area does not meet either requirement. It is defined in 42 CFR section 36.10 (1999) as “a geographic area designated pursuant to § 36.15 * * The Indian Health Service designates geographic areas, including Indian reservations and areas surrounding reservations, as Health Service Delivery Areas. 42 CFR § 36.15(a) (1999). The purpose of the Health Services Delivery Areas is to provide certain enumerated health services to qualified American Indians and natives of Alaska. See, e.g., 42 CFR § 36.1, 36.11, and 36.12 (1999). Subsection (c) of 42 CFR section 36.15 states that “the Indian Health Service may designate States, subdivisions of States such as counties or towns, or other identifiable geographic areas * * * as Health Service Delivery Areas where reservations are nonexistent, or so small and scattered and the eligible Indian population so widely dispersed that it is inappropriate to use reservations as the basis for defining the Health Service Delivery Area.” According to the testimony, 11 counties in Oregon are designated Health Service Delivery Areas. Lincoln County, where Plaintiff resides, is one of the 11 counties so designated.

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Related

Foreman v. Department of Revenue
18 Or. Tax 476 (Oregon Tax Court, 2005)

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Bluebook (online)
16 Or. Tax 166, 1999 Ore. Tax LEXIS 38, Counsel Stack Legal Research, https://law.counselstack.com/opinion/spang-v-department-of-revenue-ortc-1999.