Waters v. Comm'r Revenue

920 N.W.2d 613
CourtSupreme Court of Minnesota
DecidedDecember 5, 2018
DocketA18-0580
StatusPublished

This text of 920 N.W.2d 613 (Waters v. Comm'r Revenue) is published on Counsel Stack Legal Research, covering Supreme Court of Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Waters v. Comm'r Revenue, 920 N.W.2d 613 (Mich. 2018).

Opinion

ANDERSON, Justice.

*614Relators Charles and Anita Waters appeal from an order of the tax court that upheld the decision of respondent Commissioner of Revenue to include Pell grants in its calculation of relators' household income, which is used to determine their eligibility for, and the amount of, a property tax refund. Household income includes, among other things, "nontaxable scholarship or fellowship grants." Minn. Stat. § 290A.03, subd. 3(a)(2)(xiii) (2018).1 Relators argue that a Pell grant is neither a "scholarship" nor a "fellowship" within the meaning of this statutory language. The Commissioner argues that "nontaxable scholarship or fellowship grants" is plain and unambiguous and includes Pell grants. Because we agree with the Commissioner, we affirm the decision of the tax court.

FACTS

In 2014, Charles and Anita Waters applied for and received a property tax refund of $1,448.55, which was calculated based on the household income reported by relators. Later, the Commissioner determined that relators had underreported their household income by failing to include $4,263 in Pell grants.2 The Commissioner recalculated relators' refund, rescinded the 2014 refund, and assessed relators $232 in additional taxes.

Relators challenged the Commissioner's order in the tax court. Applying the plain language of the statute, the tax court granted the Commissioner's motion for summary judgment, concluding that "household income" for the purpose of calculating a property tax refund is unambiguous and includes "both 'nontaxable scholarship ... grants' and 'nontaxable ... fellowship grants.' " Waters v. Comm'r of Revenue , No. 9034-R, 2018 WL 1475976, at *8 (Minn. T.C. Mar. 12, 2018). The court held that, under this reading, "it does not matter whether the Pell grant is a 'scholarship grant' or a 'fellowship grant': if it is nontaxable, it is nevertheless included in the calculation of household income for purposes of the property tax refund program." Id.

Relators sought review by certiorari of the tax court's interpretation of Minn. Stat. § 290A.03. Relators maintain that Pell grants are not scholarships or fellowships and therefore cannot be included in the household income calculation made to determine the amount of the property tax refund.

ANALYSIS

An order of the Commissioner of Revenue is prima facie valid. Minn. Stat. § 271.06, subd. 6(a) (2018). A taxpayer bears the burden of presenting evidence to rebut this presumption. Conga Corp. v. Comm'r of Revenue , 868 N.W.2d 41, 53 (Minn. 2015). Statutory interpretation is a question of law reviewed de novo.

*615Antonello v. Comm'r of Revenue , 884 N.W.2d 640, 643-44 (Minn. 2016).

Here, the tax court granted the Commissioner's summary judgment motion, concluding that there was no genuine issue of material fact as to the amounts of the Pell grants relators received, and the plain language of the statute, Minn. Stat. § 290A.03, subd. 3(a)(2)(xiii), demonstrated that the Commissioner was entitled to judgment as a matter of law. The only issue before us is whether the tax court erred in its interpretation of the relevant statutory language. See Minn. Stat. § 271.10, subd. 1 (2018). A Minnesota taxpayer may be eligible for a property tax refund if the taxpayer's property taxes exceed a certain percentage of the taxpayer's "household income." See Minn. Stat. § 290A.04, subd. 1 (2018). The first step in determining refund eligibility is to calculate the taxpayer's "household income," which includes "all income received by all persons of a household in a calendar year," excluding the income of a dependent. Minn. Stat. § 290A.03, subd. 5 (2018). "Income," in turn, is defined as "the sum of ... federal adjusted gross income" plus certain additional categories of income that are not included in federal adjusted gross income. Id. , subd. 3(a)(1)-(2) (2018).

The issue in this appeal is whether the phrase "nontaxable scholarship or fellowship grants" includes Pell grants.3 We turn first to describing the nature of Pell grants and the purposes served by those grants. Pell grants are federal need-based grants awarded to low-income undergraduate and certain postbaccalaureate students to provide access to postsecondary education. See 20 U.S.C. § 1070 (2012) ; Federal Pell Grant Program , U.S. DEP'T. EDUC. , https://www2.ed.gov/programs/fpg/index.html (last updated June 4, 2015) [opinion attachment]. The amount awarded depends on the institution's cost of attendance, the student's need, and the student's enrollment status. See 20 U.S.C. § 1070a (2012) ; Federal Pell Grant Program , supra. Pell grants can be directly awarded to an institution, directly paid to the student, or both. Federal Pell Grant Program , supra.

We now turn to the plain language of the statute at issue. When interpreting a statute, our goal is to "ascertain and effectuate the intent of the Legislature." State v. Henderson , 907 N.W.2d 623, 625 (Minn. 2018). "We read a statute as a whole and give effect to all its provisions." Id. When the language of the statute is unambiguous, we apply the plain meaning. Id. We look to dictionary definitions when determining the plain and ordinary meaning of a word or phrase. State v. Haywood , 886 N.W.2d 485, 488 (Minn. 2016).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

ILHC OF EAGAN, LLC v. County of Dakota
693 N.W.2d 412 (Supreme Court of Minnesota, 2005)
Commissioner of Revenue v. Richardson
302 N.W.2d 23 (Supreme Court of Minnesota, 1981)
Michael and Jean Antonello v. Commissioner of Revenue, Relator.
884 N.W.2d 640 (Supreme Court of Minnesota, 2016)
State of Minnesota v. David Lee Haywood
886 N.W.2d 485 (Supreme Court of Minnesota, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
920 N.W.2d 613, Counsel Stack Legal Research, https://law.counselstack.com/opinion/waters-v-commr-revenue-minn-2018.