W. VA. TRACTOR & EQUIPMENT CO. v. Hardesty

280 S.E.2d 270, 167 W. Va. 511, 1981 W. Va. LEXIS 656
CourtWest Virginia Supreme Court
DecidedJuly 14, 1981
Docket14426, 14427
StatusPublished
Cited by5 cases

This text of 280 S.E.2d 270 (W. VA. TRACTOR & EQUIPMENT CO. v. Hardesty) is published on Counsel Stack Legal Research, covering West Virginia Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
W. VA. TRACTOR & EQUIPMENT CO. v. Hardesty, 280 S.E.2d 270, 167 W. Va. 511, 1981 W. Va. LEXIS 656 (W. Va. 1981).

Opinion

Neely, Justice:

These cases were consolidated in this Court to determine whether certain lease and lease/purchase agreements should be considered as sales or rentals for the purposes of the State’s Business and Occupation Tax. The transactions in question involve heavy machinery used in construction and surface mining. Both appellees engage in the sales, service and rental of such machinery. Many of the customers of appellees cannot afford to buy new equipment when needed, either because of the large down payment required, or because incurring debts of that magnitude would make pre-qualification and bonding for state road projects more difficult and expensive. To facilitate sales in these situations the appellee companies follow the trade practice of allowing their customers to lease the equipment initially. In general, the customer is required to keep the equipment and pay rent for at least six months. However, at any time during the six month period the customer may buy the equipment outright and apply to the down payment all of the rental payments already made.

If the customer does not buy the equipment during the first six months and wants to keep it longer, he may continue to lease it from month to month while retaining an option to buy. Both appellees transfer title to customers when the sum of monthly payments equals the initial purchase price of the equipment plus a finance charge. Such sales are called lease payouts. In effect, then, there are two methods by which equipment can be purchased: the exercise of the option to buy and the lease payout. Most of *513 these agreements are oral, but at times they are written. While the written agreements specifically disclaim any purchase options, both appellees demonstrate that this disclaimer is routinely waived orally. 1

*514 During the contract period the appellees retain title to the equipment but they require their customers to insure it. The customers pay all personal property taxes for the equipment while it is in their possession. Appellees do not take depreciation on the equipment nor do they take *515 investment tax credits, and their customers treat their payments as expenditures for capital, not rent payments, for federal tax purposes. The Internal Revenue Service characterizes these lease agreements as sales because the purchase option is exercisable within a period clearly less than the expected life of the equipment and the rental payments cover a substantial portion of the costs of the equipment, see I.R.C. § 162(a) (1976); Rev. Rul. 540, 1955-2 C.B. 39. The conclusion that the parties intend sales to transpire is supported by the fact that 95% of the equipment leased by appellee Wright-Thomas eventually is sold to lessees and 70% of appellee West Virginia Tractor’s dollar sales volume is derived from what were initially lease agreements.

If these agreements are sales, they enjoy a lower tax rate under W. Va. Code, 11-13-2(c) [1971] than if they are leases *516 of equipment, Code, 11-13-2(i) [1971]. Taxpayers prevailed in their appeal to the Circuit Court of Kanawha County from a ruling by the State Tax Commissioner which held these transactions to be leases. The circuit court concluded, however, that the substance and not the form of a transaction is decisive for tax purposes and it held that the lease/purchase arrangements should be taxed at the lower sales rate. The Tax Commissioner now appeals from that decision. We disagree with the circuit court’s ruling and therefore we reverse.

I

Appellees claim that for all practical purposes they consider these agreements sales, not the furnishing of property for hire. They conclude, therefore, that their income from the lease transactions should be taxed at the rate for wholesale sales, Code, 11-13-2(c) [1971] because in substance they are sales, or alternatively, because they are necessary to and thus included in the business of wholesale sales. Appellant Tax Commissioner claims, however, that regardless of the parties’ intentions, the transactions are leases and should be taxed at the higher rate set for the leasing of property, Code 11-13-2(i) [1971]. While the leases may be convenient for appellees, they are not part of the business of selling at wholesale.

Appellees’ argument is essentially that their tax should be assessed on the basis of the substance of their transactions, not the form. However, tax law is a creature of statute and it is the statute which determines the issue. It is well settled in this State that when a tax statute is clear and free from ambiguity, it will be applied and not construed. State ex rel. Hardesty v. Aracoma-Chief Logan No. 4523, V.F.W., 147 W. Va. 645, 129 S.E.2d 921, 924 (1963); J. D. Moore, Inc. v. Hardesty, 147 W. Va. 611,129 S.E.2d 722, 724-25 (1963). In Code, 11-13-1 [1971], sales are defined to include “any transfer of the ownership of or title to property.” It is clear that appellees are not engaged in sales because the transactions by their own terms do not involve the transfer of ownership or title in the property. Unless the lessee chooses to buy the equipment at the end of the *517 rental period he has received nothing for his money other than the use of the equipment during the rental period.

Moreover, the written agreements in the record all call themselves leases and disclaim any options to buy. 2

In other cases we have noted that the actual rights and duties owed to third parties and the rest of the world which are established by the terms of taxpayers’ transactions are controlling for purposes of the Business and Occupation Tax, see, e.g., Frazee Lumber Co. v. Haden, 156 W.Va. 844, 197 S.E.2d 634 (1973) (since contract between taxpayer and third party clearly identifies taxpayer as timber producer, he is liable as such under Code, 11-13-2(a)); State ex rel. Hardesty v. Aracoma-Chief Logan No. 4523, V.F.W., 147 W.Va. 645, 129 S.E.2d 921 (1961) (when fraternal lodge holds itself out to public as caterer for profit, in competition with commercial restaurants and caterers, income from such catering is not exempt from tax on sales, Code, 11-13-2(c), as income of charitable organization, Code, 11-13-3). In the .cases before us, the rights and duties of appellees are established in the agreements they chose to call leases, not sales. The terms of the agreements provide for the customers’ use of the equipment, not ownership. The agreements do not provide the customers with any interest in the property.

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Bluebook (online)
280 S.E.2d 270, 167 W. Va. 511, 1981 W. Va. LEXIS 656, Counsel Stack Legal Research, https://law.counselstack.com/opinion/w-va-tractor-equipment-co-v-hardesty-wva-1981.