Sturgis Air One, L.L.C. v. Harris County Appraisal District

CourtCourt of Appeals of Texas
DecidedMarch 24, 2011
Docket14-09-00891-CV
StatusPublished

This text of Sturgis Air One, L.L.C. v. Harris County Appraisal District (Sturgis Air One, L.L.C. v. Harris County Appraisal District) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sturgis Air One, L.L.C. v. Harris County Appraisal District, (Tex. Ct. App. 2011).

Opinion

Affirmed and Opinion filed March 24, 2011.

In The

Fourteenth Court of Appeals

___________________

NO. 14-09-00891-CV

Sturgis Air One, L.L.C., Appellant

V.

Harris County Appraisal District, Appellee

On Appeal from the 127th Judicial District Court

Harris County, Texas

Trial Court Cause No. 2007-36992

OPINION

Sturgis Air One, L.L.C. (“Sturgis”) challenges the district court’s ruling denying its motion for summary judgment and granting the cross-motion for summary judgment of the Harris County Appraisal District (“HCAD”). At issue is the final property tax assessment of Sturgis’s privately owned jet.

On appeal, we examine section 21.055 of the Texas Tax Code, a provision that establishes a tax entitlement for aircraft moving in interstate commerce. Section 21.055 states the following:

If an aircraft is used for a business purpose of the owner, is taxable by a taxing unit, and is used continually outside this state, whether regularly or irregularly, the appraisal office shall allocate to this state the portion of the fair market value of the aircraft that fairly reflects its use in this state. The appraisal office shall not allocate to this state the portion of the total market value of the aircraft that fairly reflects its use beyond the boundaries of this state.

Tex. Tax Code Ann. § 21.055(a) (West 2008). The entitlement is known as “interstate allocation,” and its calculation is prescribed by the following formula:

The allocable portion of the total fair market value of an aircraft described by Subsection (a) is presumed to be the fair market value of the aircraft multiplied by a fraction, the numerator of which is the number of departures by the aircraft from a location in this state during the year preceding the tax year and the denominator of which is the total number of departures by the aircraft from all locations during the year preceding the tax year.

Id. § 21.055(b).

We must determine whether the right provided by Section 21.055 was waived when Sturgis failed to timely report (or “render”) its aircraft to the taxing authority. If the right was not so waived, we must also decide whether Sturgis provided enough information at the time of rendition to prove its entitlement to interstate allocation. Reaching only the first question, we hold that Sturgis waived its right to interstate allocation by failing to render the aircraft by the statutory deadline. We therefore affirm.

FACTS

Sturgis is a transportation company duly formed under the laws of the U.S. Virgin Islands. Its principal place of business is in Christiansted on the island of St. Croix. Since 2003, Sturgis has leased a 1991 Cessna 560 to Allied Home Mortgage Capital Corporation, a Texas corporation with hundreds of offices throughout the United States. Jim Hodge, the president of Allied Home, also serves as the manager of Sturgis, and he uses the aircraft to travel between his various offices nationwide. When not in service, the aircraft is frequently hangared at Hooks Airport in northwest Harris County, just outside Hodge’s residence in Spring. Investigators with HCAD discovered the aircraft hangared there in August 2006.

Before 2006, Sturgis had never rendered the aircraft for property tax purposes to any taxing authority, foreign or domestic. HCAD believed it may have the jurisdiction to tax the aircraft and wrote to Sturgis requesting information for determining its taxable situs. The letter was addressed to Sturgis’s office in the Virgin Islands and stated that HCAD may assess back taxes on the aircraft for tax years 2005 and 2006. See id. § 25.21 (directing appraisals for the two preceding years on personal property omitted from the tax rolls). Sturgis never responded to the letter, and in September 2006, HCAD sent a Notice of Appraised Value, appraising the aircraft at $3,101,000. Included with the notice was an estimate of Sturgis’s tax liability for tax year 2006, which projected a final tax based on the aircraft’s fully appraised market value.

In October 2006, before a final tax was assessed, Sturgis officially rendered the aircraft for tax year 2006. The rendition for tax year 2005 followed in November 2006. For each tax year, Sturgis used a standardized rendition form that allows a taxpayer to request interstate allocation. To complete the request for a business aircraft, the property owner must report the number of revenue departures the aircraft made from Texas, as well as the total number of departures made during the tax year.

For tax year 2005, Sturgis reported that the aircraft departed from Texas 70 times, with 149 total departures for the year. For tax year 2006, Sturgis reported 30 departures from Texas out of a total of 87 for the year. As a supplement, Sturgis also submitted a flight log for tax year 2006, summarizing the dates and locations of each departure. Based on these figures, Sturgis sought to apportion its final tax in Texas to roughly 47% of the aircraft’s actual value for 2005, and 35% of its value for 2006.

HCAD ultimately refused the apportionment request, assessing a final tax at the aircraft’s full market value instead. Because Sturgis rendered the aircraft after the April 15 deadline for each tax year, HCAD also assessed a statutory penalty amounting to ten percent of the taxes imposed on the property. See id. §§ 22.23, 22.28. After unsuccessfully protesting the final assessment in administrative proceedings, Sturgis filed suit for judicial review in the district court, where both parties moved for summary judgment. See id. § 42.01.

In its motion for summary judgment, Sturgis asserted that it was entitled to interstate allocation because it complied with all statutes and regulations, notwithstanding the untimely rendition. HCAD filed a combined traditional and no-evidence motion for summary judgment. In its traditional motion, HCAD claimed that Sturgis was not entitled to interstate allocation because it rendered the aircraft after the statutory deadline, thereby waiving the entitlement as a matter of law. In its no-evidence motion, HCAD asserted that Sturgis failed to submit any evidence that the aircraft had acquired a taxable situs outside of Texas. The district court denied Sturgis’s motion and granted HCAD’s cross-motion in its entirety. Sturgis now appeals to us.

STANDARD OF REVIEW

We review the district court’s summary judgment de novo. Provident Life & Accident Ins. Co. v. Knott, 128 S.W.3d 211, 215 (Tex. 2003).

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Sturgis Air One, L.L.C. v. Harris County Appraisal District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sturgis-air-one-llc-v-harris-county-appraisal-district-texapp-2011.