Williams v. State Tax Assessor State Tax Assessor

CourtSuperior Court of Maine
DecidedJune 26, 2002
DocketKENap-99-89
StatusUnpublished

This text of Williams v. State Tax Assessor State Tax Assessor (Williams v. State Tax Assessor State Tax Assessor) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Williams v. State Tax Assessor State Tax Assessor, (Me. Super. Ct. 2002).

Opinion

STATE OF MAINE SUPERIOR COURT KENNEBEC; ss. CIVIL ACTION DOCKET NO. AP-99-89

DONALD J. WILLIAMS,

Petitioner Vv. ORDER ON SUMMARY JUDGMENT STATE TAX ASSESSOR, DONALD L GARBRECEHT Respondent JUL 18 2002

This matter is before the court on the State Tax Assessor’s Motion for Summary

Judgment on petition for review of final agency action filed pursuant to MR. Civ. P.

80C. For the reasons explained below, the motion for summary judgment is granted.

I. Facts and Procedural History

Petitioner Donald Williams (Williams) has brought an 80C appeal seeking judicial review of a decision by the State Tax Assessor (Assessor) to issue him a supplemental assessment for tax year 1988 pursuant to M.R.S.A. § 141 (1990 & Supp. 2001). This is the second assessment regarding Williams income tax liability for 1988. In July, 1995, Williams was assessed a tax of $102,275, plus interest and penalties, for income derived from the sale of a concrete plant in Leeds, Maine in 1988.1 Williams appealed the assessment to this court [hereinafter Williams I], based largely upon the issue of his 1988 state residency, and a trial was commenced in August, 2000. On the third day of trial, the parties settled and a settlement agreement and consent judgment were drafted

and signed.

1 The record indicates Williams filed his 1988 individual Federal 1040 return in January 1993 and his 1988 Maine 1040 in May, 1996. While Williams I was pending, the Assessor reviewed Williams’ capital gain income for 1988 and found he underreported $556,800 by improperly claiming contingent liabilities totalling that amount. In May, 1998, Williams was issued a second assessment for 1988 adding up to $129,205 in tax, interest and penalties. Following a reconsideration upholding the assessment, Williams has petitioned this court for review. In his petition, Williams alleges six separate counts in which the second assessment was erroneous. This court will address each of these counts individually as the Assessor has moved for summary judgment on all of the allegations set forth in the petition.

II. Discussion

A. Standard of Review

Summary judgment is appropriate if the record reflects that there is no genuine issue of material fact and the moving party is entitled to a judgment as a matter of law. MLR. Civ. P. 56(c); Saucier v. State Tax Assessor, 2000 ME 8, 7 4, 745 A.2d 972, 974. "A genuine issue of material fact is present only when 'there is sufficient evidence supporting the claimed factual dispute to require a choice between the parties’ differing versions of the truth at trial.'" Francis v. Stinson, 2000 ME 173, J 37, 760 A.2d 209, 217 (quoting Prescott v. State Tax Assessor, 1998 ME 250, J 5, 721 A.2d 169, 171-72).

The Superior Court serves as the forum of origin for a determination of both facts and law when reviewing decisions of the State Tax Assessor. 36 M.R.S.A. § 151 (1990 & Supp. 2001). On review of a decision of the Assessor, this court “shall conduct a de novo hearing and make a de novo determination of the merits of the case. It shall make its own determination as to all questions of fact or law.” Id. “The burden of

proving that a transaction was not taxable shall be upon the person charged with tax liability.” 36 M.R.S.A. § 1763 (1990); see also 36 M.R.S.A. § 151 (“The burden of proof is on the taxpayer.”). “The well settled principle that taxation is the rule and tax exemption is the exception places the burden on the [taxpayer] to bring its request unmistakably within the spirit and intent of the claimed exemption.” SST & 5S, Inc. v. State Tax Assessor, 675 A.2d 518, 521 (Me. 1996).

B. Authority of State Tax Assessor

As a threshold matter, the petitioner questions the validity of the Assessor’s investigation. He contends the Assessor is required to assess the tax based on the taxpayer’s federal adjusted gross income and any actions taken to recalculate this amount are ultra vires. He relies on the holding of Tiedemann v. Johnson, 316 A.2d 359 (Me. 1974) for the principle that federal adjusted gross income represents the entire taxable income of a Maine resident.

Title 36 M.R.S.A. § 5121 defines taxable income as “that individual’s federal

adjusted gross income as defined by federal law ...” (emphasis added). Since state law requires that the Assessor use a taxpayer’s adjusted gross income as defined by federal law, he may then look to federal law to determine whether the taxpayer’s adjusted gross income is legally correct, consistent with 36 M.R.S.A. §§ 141, 5121. The Assessor

contends that, under Maine law, the starting point for determining Maine adjusted

gross income is the figures that appears on an individual’s federal return for adjusted gross income. Green v. State Tax Assessor, 562 A.2d 1217, 1219. (Me. 1989) (emphasis added). The Green court explained the holding in Tiedemann by stating that “[w]e explicitly rejected in Tiedemann the argument advanced by plaintiffs . . . that the Maine Legislature intended that Maine income tax law mirror the federal scheme of income

taxation.” Green, 562 A.2d at 1220. Maine adjusted gross income is defined as “the federal adjusted gross income of that individual,” with allowable statutory modifications. 36 M.R.S.A. § 5102(1-C). Tiedemann and Green require the Assessor to interpret Maine tax law without reference to federal law, except where terms are not defined under state law. See also 36 M.R.S.A. § 5102(11). On the other hand, where state law requires definition under federal law, the Assessor must follow federal law. See 36 M.R.S.A. § 5121. As the Assessor appears to have properly understood his duty to interpret the applicable federal tax provisions in reviewing the petitioner’s 1988 Maine return, this court finds that the Assessor actions are not ultra vires.

C. Williams’ Residency for Tax Year 1988.

The Assessor argues that Williams is barred by the doctrine of collateral estoppel from claiming he was not a Maine resident when he received the $556,800 in capital gain. The Assessor maintains that, based on a paragraph from the settlement agreement in Williams I, the issue of Williams’ residency in both 1988 and 1989 is precluded. Paragraph 5 from the settlement agreement reads “Mr. Williams agrees that he has been a resident individual of Maine since no later than May 1, 1987, within the meaning of 36 M.R.S.A. § 5102(5).” Record, Vol I, Sect. 2, Exh. A.

Williams raises little argument with his Maine residency for 1988, but takes great exception to any use of the settlement agreement paragraph to determine his residency for subsequent years because the litigation in Williams I dealt solely with the 1988 tax year.

Collateral estoppel, or "issue preclusion," prevents the reopening in a second action of an issue of fact actually litigated and decided in an earlier case "if the identical issue was determined by a prior final judgment, and the party estopped had a fair

opportunity and incentive to litigate the issue in a prior proceeding.” Cline v. Maine Coast Nordic, 1999 ME 72, J 9, 728 A.2d 686, 688 (quotation and citation omitted).

The central issue here, as in Williams I, is Williams’ 1988 residency for tax liability purposes. He had a full and fair opportunity to litigate the issue, as evidenced by three days of trial testimony, with similar motivation to litigate (avoidance of tax liability), and the settlement agreement clearly references Williams’ admission of Maine residency after May, 1987.

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Related

Arrowsmith v. Commissioner
344 U.S. 6 (Supreme Court, 1952)
Frank v. Assessors of Skowhegan
329 A.2d 167 (Supreme Judicial Court of Maine, 1974)
Cline v. MAINE COAST NORDIC
1999 ME 72 (Supreme Judicial Court of Maine, 1999)
Hyland v. Commissioner of Internal Revenue
175 F.2d 422 (Second Circuit, 1949)
Prescott v. State Tax Assessor
1998 ME 250 (Supreme Judicial Court of Maine, 1998)
Francis v. Stinson
2000 ME 173 (Supreme Judicial Court of Maine, 2000)
Central Maine Power Co. v. Public Utilities Commission
405 A.2d 153 (Supreme Judicial Court of Maine, 1979)
Barnes v. Zappia
658 A.2d 1086 (Supreme Judicial Court of Maine, 1995)
Walsh v. City of Brewer
315 A.2d 200 (Supreme Judicial Court of Maine, 1974)
Jackson Advertising Corp. v. State Tax Assessor
551 A.2d 1365 (Supreme Judicial Court of Maine, 1988)
Green v. State Tax Assessor
562 A.2d 1217 (Supreme Judicial Court of Maine, 1989)
Saucier v. State Tax Assessor
2000 ME 8 (Supreme Judicial Court of Maine, 2000)
SST & S, INC. v. State Tax Assessor
675 A.2d 518 (Supreme Judicial Court of Maine, 1996)
Tiedemann v. Johnson
316 A.2d 359 (Supreme Judicial Court of Maine, 1974)
Levine v. R.B.K. Caly Corp.
2001 ME 77 (Supreme Judicial Court of Maine, 2001)
Sproull v. Commissioner
16 T.C. 244 (U.S. Tax Court, 1951)

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Williams v. State Tax Assessor State Tax Assessor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/williams-v-state-tax-assessor-state-tax-assessor-mesuperct-2002.