Sprint Communications Co. v. State Board of Equalization

40 Cal. App. 4th 1254, 47 Cal. Rptr. 2d 399, 95 Daily Journal DAR 16305, 95 Cal. Daily Op. Serv. 9389, 1995 Cal. App. LEXIS 1197
CourtCalifornia Court of Appeal
DecidedDecember 8, 1995
DocketA067452
StatusPublished
Cited by5 cases

This text of 40 Cal. App. 4th 1254 (Sprint Communications Co. v. State Board of Equalization) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sprint Communications Co. v. State Board of Equalization, 40 Cal. App. 4th 1254, 47 Cal. Rptr. 2d 399, 95 Daily Journal DAR 16305, 95 Cal. Daily Op. Serv. 9389, 1995 Cal. App. LEXIS 1197 (Cal. Ct. App. 1995).

Opinion

Opinion

PETERSON, P. J.

On this appeal we hold that: (1) the State Board of Equalization (Board) may set off, against a taxpayer’s timely claim for refund of overpayment of use taxes, all time-barred (but otherwise valid) underpayments of use taxes on other transactions which were not made during the same period for which refund is claimed; (2) a taxpayer’s agreement extending the Board’s statutory time to mail notice of use tax deficiencies for the period encompassing both its refund claim period and a stated additional period does not subject that taxpayer’s overpayment refunds to setoff for underpayment of time-barred (but otherwise valid) use taxes occurring thereafter.

I. Facts and Procedural Background

The Board appeals from a judgment awarding Sprint Communications Company L.P. (Sprint) $197,450.25 in its action for refund of use taxes. (Rev. & Tax. Code, 1 § 6933.) Sprint overpaid use taxes on property it purchased for use outside California; and on April 20, 1990, Sprint filed a claim, conceded to be timely, for refund of those overpayments. The Board conducted an audit on this claim. While the audit was pending, Sprint and the Board executed two waiver agreements to extend the Board’s time to mail notices of deficiency determinations to Sprint as required by section 6487. 2 We will hereafter deal with issues affected by the following three periods:

*1258 (1) The refund claim period. Sprint’s refund claim was for its overpayments of use tax in the fourth quarter of 1986 through the third quarter of 1988 (Oct. 1, 1986, through Sept. 30, 1988).
(2) The extension periods. The initial waiver agreement added the last quarter of 1988 (Oct. 1, 1988, through Dec. 31, 1988) (first extension period) to the period to be audited by the Board, and extended the Board’s time to mail Sprint a notice of deficiency covering the refund claim period and the first extension period. Before the first extension period expired, the second waiver agreement added the first two quarters of 1989 (Jan. 1, 1989, through June 30, 1989) (second extension period) to the period to be audited by the Board, and once again extended the Board’s time to mail Sprint a notice of deficiency determination through October 31, 1992, covering the entire time commencing with the first quarter of Sprint’s refund claim period (beginning Oct. 1, 1986) through all extension periods (ending June 30, 1989).
(3) The nonwaived period. The Board then, without further agreement from Sprint, included in its audit the third quarter of 1989 (July 1, 1989, through Sept. 30,1989). Sprint never extended the time for filing a notice of deficiency determination for the nonwaived period. The three-year period in which to do so expired prior to November 20, 1992, the day the Board finally mailed its notice of deficiency/refund determination to Sprint for the entire period of the audit it made (Oct. 1, 1986, through Sept. 30, 1989).

The Board, thus, mailed an untimely notice of deficiency determination beyond the last stipulated extension date therefor of October 31,1992, for all quarters except the third quarter of 1989 (the nonwaived period). As to that last quarter of its audit (July 1, 1989, through Sept. 30,1989), the notice was mailed after the period permitted by section 6487—within three years after October 31, 1989.

In summary:

(1) The Board approved overpayment refunds to Sprint totaling approximately $744,000 for the refund claim period, and set off against that sum time-barred but otherwise valid claims of about $230,000 for use tax underpayment on other transactions in the same period (Oct. 1, 1986, through Sept. 30, 1988).
(2) The Board found Sprint had overpaid its use tax for the first and second extension periods without any setoff of time-barred tax underpayments occurring during those periods (Oct. 1, 1988, through June 30, 1989) and credited those overpayments to Sprint.
*1259 (3) The Board found Sprint had underpaid its use tax by $13,955.26 and had made no overpayments in the nonwaived period (July 1, 1989, through Sept. 30, 1989); the Board set off that underpayment of $13,955.26 against the total refunds due Sprint for the refund claim period.
(4) All use tax deficiencies credited by the Board against Sprint’s refund claims were unenforceable under the limiting provisions of section 6487. They totaled $243,972.11.

As framed by the pleadings, the legal issue presented was “whether the Board may retain amounts erroneously paid by Sprint on account of tax exempt purchases, and apply those amounts to tax deficiencies on other transactions after the time for enforcing those deficiencies has expired.’’ Sprint concedes that the tax deficiencies would have been properly assessed if the three-year statute of limitations for giving notice, as extended by agreement, had not run. (§ 6487.) Sprint’s principal contention, however, is that the running of the statute of limitations, as extended by the waiver agreements, proscribes the Board’s power to set off the deficiencies against the refund. We review this issue de novo. (Heller v. Franchise Tax Bd. (1994) 21 Cal.App.4th 1730, 1735 [27 Cal.Rptr.2d 88].)

II. Discussion

A. Equitable Setoff of Time-barred Use Tax Underpayments Not Made During the Taxpayer’s Refund Claim Period

Sprint’s claim is predominately directed to the Board’s setoff of underpayments of use taxes which occurred during the refund claim period, and we deal first with this issue. The context in which this dispute arises—a taxpayer’s suit for refund of taxes—is extremely important to its resolution. “[S]ince a suit for a refund of taxes is governed by equitable principles, a plaintiff who challenges the validity of a tax may recover only if it be shown that more has been exacted than in equity and good conscience should have been paid.” (Goodwill Industries v. County of L. A. (1953) 117 Cal.App.2d 19, 27 [254 P.2d 877]; Northrop Aircraft v. Cal. Emp. etc. Com. (1948) 32 Cal.2d 872, 879 [198 P.2d 898] (Northrop); Pacific Fruit Express Co. v. McColgan (1944) 67 Cal.App.2d 93, 96-97 [153 P.2d 607].) The equitable principles underlying a refund action “limit recovery to the difference between the tax actually paid and that which properly should have been exacted, and . . . prevent recovery if the taxpayer paid only his fair and just proportion of taxes.” (Simms v. County of Los Angeles

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40 Cal. App. 4th 1254, 47 Cal. Rptr. 2d 399, 95 Daily Journal DAR 16305, 95 Cal. Daily Op. Serv. 9389, 1995 Cal. App. LEXIS 1197, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sprint-communications-co-v-state-board-of-equalization-calctapp-1995.