Uniformed Services Benefit Ass'n v. United States

727 F. Supp. 533, 11 Employee Benefits Cas. (BNA) 2643, 65 A.F.T.R.2d (RIA) 628, 1990 U.S. Dist. LEXIS 60, 1990 WL 226
CourtDistrict Court, W.D. Missouri
DecidedJanuary 3, 1990
DocketNo. 88-0234-CV-W-6
StatusPublished

This text of 727 F. Supp. 533 (Uniformed Services Benefit Ass'n v. United States) is published on Counsel Stack Legal Research, covering District Court, W.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Uniformed Services Benefit Ass'n v. United States, 727 F. Supp. 533, 11 Employee Benefits Cas. (BNA) 2643, 65 A.F.T.R.2d (RIA) 628, 1990 U.S. Dist. LEXIS 60, 1990 WL 226 (W.D. Mo. 1990).

Opinion

MEMORANDUM AND ORDER

SACHS, District Judge.

Plaintiff Uniformed Benefit Services Association (USBA) filed suit against the defendant United States of America (Government), seeking a refund of $712,155.61 in taxes and interest. The parties have submitted the case to the court on stipulated facts. The following statement of facts is drawn from that stipulation.

The plaintiff seeks a refund of taxes paid for the 1978 and 1979 tax years. During those years the USBA was a voluntary employee’s benefit association, exempt from taxation under 26 U.S.C. § 501(e)(9). Such organizations are, however, subject to taxation for unrelated business income. See § 512. The association provides its members with insurance products consisting of life and accidental death and dismemberment benefits. USBA derives its revenues from premiums paid by members, from other fees and from investments. The income from sources other than insurance premiums is placed in a fund designated as the Operating Fund. Income placed in that fund is reported to the IRS as “set aside for payment of costs of administration of Association benefit programs.” It is therefore exempt from taxation pursuant to § 512(a)(3)(B).

Income removed from the Operating Fund and spent for other than the designated purposes is subject to taxation as unrelated business income. Id. The dispute in the instant case arises from USBA’s withdrawal of funds to purchase a new office building and a new computer system. Both the usable space in the building and the computer capacity exceeded USBA’s needs for the taxable years. The Government subsequently assessed taxes against the plaintiff for the portions of the cost of the building and of the computer system that could be attributed to the excess capacity.

The parties stipulate that both purchases were reasonable and prudent business decisions. USBA had experienced considerable growth in the years prior to the purchases, and foresaw a similar level of growth in the coming years. At that time, it leased office space that no longer provided adequate space for its current or projected future needs. The association conducted a study of its requirements for office accommodations in light of its projected growth, and concluded that between 15,000 and 25,-000 square feet would be necessary.

Subsequently, USBA embarked on a search for property that would satisfy those requirements. The plaintiff reviewed several options, including rental of space and the purchase of land for the construction of a new facility. USBA rejected those options either because the properties did not meet its needs for projected growth or because it considered the cost per square foot to be too high. The proposed construction project would have cost more, but provided fewer square feet, than the building that the plaintiff finally purchased.

USBA paid $1.3 million to Continental Casualty Company (CNA) for a building containing 52,900 square feet of rentable space. CNA required USBA to lease approximately 30,000 square feet of the building back to it for five years as a condition of the purchase. USBA rented other excess space in the building under short term leases. Before the purchase, USBA as lessee rented 6,000 square feet in the Midland building for its staff and rented storage space in other buildings. During the tax year in question (1978) USBA occupied 25% of the available space in the new building and appropriately rented out the remaining space. Since the purchase, the USBA has occupied steadily increasing proportions of the building, occupying approximately 85% of the available space in December 1988.

In 1978 USBA sought additional computer capacity. As was the case with the acquisition of the new building, an increasing need for computer time accompanied the association’s growth. USBA fulfilled this need through a joint venture with the [535]*535unrelated Armed Forces Cooperative Insuring Association (AFCIA). Together the associations purchased a computer system and formed a corporation to control the system. Each association would have a right to 50% of the system’s capacity. The corporation could sell any of the computer capacity that the associations did not use. During the taxable year ending May 31, 1979, USBA used 90-100% of the computer capacity available to it. USBA’s needs subsequently exceeded the computer capacity. The system has been upgraded four times since 1979.

In audits of the 1978 and 1979 tax years, the IRS determined that the purchase of excess building capacity and excess computer capacity out of the set-aside funds contained in USBA’s Operating Fund amounted to non-exempt use of those funds. The tax commissioner determined that USBA should be liable for taxes on amounts equalling 50% of the building purchase and 8% of the computer purchase. For the tax year 1978 USBA paid $298,-500.00 in back taxes and $401,375.23 in interest for a total of $699,875.23 for the assessment on the building purchase. It paid $5,451.94 in back taxes and $6,828.44 in interest for a total of $12,280.38 on the assessment for the computer purchase in tax year 1979. The plaintiff seeks a total refund of $712,155.61.

The parties agree that the purchase of the building was the best choice among the alternatives available to USBA. They agree that it was a wise business decision. USBA, relying on Wolgin v. Simon, 722 F.2d 389 (8th Cir.1984), and Dahlem Foundation, Inc. v. United States, 405 F.2d 993 (6th Cir.1969), suggests that the court should apply the business judgment rule, which admonishes against court interference in the sound judgment of business organizations, to its board’s decision to purchase the building. The plaintiff argues that the Government’s position is contrary to that rule and that the tax assessment amounts to a penalty against USBA for providing for its reasonably anticipated future growth by purchasing excess capacity at current prices. The plaintiff urges the court to consider the funds spent in anticipation of future growth as reasonable costs of administration, and therefore, qualified for the tax exemption.

The Government responds that the reasonableness of the plaintiff’s business decision is not at issue. Because tax liability arises on an annual basis, Commissioner v. Sunnen, 333 U.S. 591, 598, 68 S.Ct. 715, 719-20, 92 L.Ed. 898 (1948), a consideration of whether the plaintiff’s purchases were necessary expenditures must be measured by the circumstances existing at the time of the transaction. The Government further points out the general rule that tax exemptions are to be narrowly construed. Therefore, the Government supports the commissioner’s conclusion that the expenditure of funds for building space that exceeded the association’s existing needs by approximately 300% was not a reasonable cost of administration.

The taxpayer who seeks a refund of taxes bears the burden of proving that it is entitled to a refund and of the amount of refund. Mercantile Bank and Trust Co. v. United States, 441 F.2d 364, 366 (8th Cir.1971).

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727 F. Supp. 533, 11 Employee Benefits Cas. (BNA) 2643, 65 A.F.T.R.2d (RIA) 628, 1990 U.S. Dist. LEXIS 60, 1990 WL 226, Counsel Stack Legal Research, https://law.counselstack.com/opinion/uniformed-services-benefit-assn-v-united-states-mowd-1990.