Justia Tax Law Opinion Summaries

Articles Posted in Maine Supreme Judicial Court
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The Supreme Judicial Court affirmed the judgment of the superior court affirming a decision of the State Board of Property Tax Review upholding the Town of Madison's denial of Madison Paper Industries' (MPI) request for a property tax abatement for the 2016-17 tax year, holding that the Board made no errors of law, and its findings were supported by competent evidence in the record.The Board found MPI's appraisal and its underlying factual assertions were not credible and that MPI had failed to meet its burden of persuasion. On appeal, MPI argued that the Board failed to apply the Maine Constitution's required that it apply the "just value" standard to valuing the property. The Supreme Judicial Court affirmed, holding that the Board's determinations were not erroneous and that its findings were supported by the evidence. View "Madison Paper Industries v. Town of Madison" on Justia Law

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The Supreme Judicial Court affirmed the judgment entered in the business and consumer docket affirming the State Tax Assessor's denial of Appellant's request for an income tax refund for the 2013 taxable year, holding that the superior court did not err.Somerset Telephone Company and affiliated corporations (collectively, Appellant) filed a 2013 Maine tax return showing positive Maine taxable income and state income tax liability. Appellant later filed an amended 2013 return listing an adjusted federal taxable income resulting in a decreased Maine taxable income and decreased tax liability. To account for the difference, Somerset unsuccessfully requested from the Assessor a partial refund. In this ensuing litigation, the business and consumer docket entered a final judgment in the Assessor's favor. The Supreme Judicial Court affirmed, holding that the superior court correctly affirmed the decision of the State Tax Assessor. View "Somerset Telephone Co. v. State Tax Assessor" on Justia Law

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The Supreme Judicial Court vacated the judgment of the superior court affirming a 2019 decision of the State Board of Property Tax Review granting the tax abatement requests of Expera Old Town, LLC for the 2014 and 2015 tax years for a wood pulp and paper mill, holding that the superior court erred.Expera Old Town, LLC requested tax abatements for 2014 and 2015, but the City of Old Town denied the requests. In 2017, the Board affirmed the City's denial of the requested abatements. The superior court vacated the Board's decision and remanded the case. On remand, in 2019, the Board granted Expera Old Town's tax abatement requests for the same tax years. The Supreme Court vacated the superior court's judgment, holding that Expera Old Town failed to meet its initial burden of showing that the assessments were manifestly wrong. View "City of Old Town v. Expera Old Town, LLC" on Justia Law

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In these cases concerning property tax abatement requests the Supreme Judicial Court affirmed two decisions of the superior court vacating a decision denying requests for abatement and granting a petition for judicial review of an adverse decision concerning another request for a tax abatement, holding that the superior court did not err.This consolidated appeal concerned property tax abatement requests made by the Roque Island Gardner Homestead Corporation (RIGHC). The superior court vacated a decision of the Board of Appeals (BOA) of the Town of Jonesport denying RIGHC's requests for abatement concerning three tax years and remanded the matter for the BOA to make an independent determination of the property's fair market value. The court also granted judicial review as to the State Board of Property Tax Review's adverse decision concerning RIGHC's request for another tax year abatement and directed the Town to grant the abatement request. The Supreme Judicial Court affirmed both decisions, holding that the superior court did not err. View "Roque Island Gardner Homestead Corp. v. Town of Jonesport" on Justia Law

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The Supreme Judicial Court vacated the superior court's grant of summary judgment concluding that the taxable "sale price" of iPhones sold at discounted prices to customers who entered into wireless service contracts at Apple Inc.'s retail stores did not include payments made by the wireless service carriers to Apple in connection with the sales, holding that the amounts paid by the carriers to Apple constitute part of the taxable sale prices for the phones.In granting summary judgment for Apple and denied the summary judgment motion filed by the State Tax Assessor the superior court concluded that the carriers' payments to Apple were insufficiently linked to the phones' purchases to constitute reimbursement for the discounts. The Supreme Judicial Court vacated the grant of summary judgment and remanded for entry of judgment in favor of the Assessor, holding that because Apple expected at the time of sale it would be reimbursed by the carriers for the price discounts granted to customers entering into wireless service contracts with the carriers, the amounts Apple paid to carriers constituted part of the taxable sale prices for the phones. View "Apple Inc. v. State Tax Assessor" on Justia Law

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The Supreme Judicial Court vacated in part and affirmed in part a summary judgment entered in the business and consumer docket that adjudicated all claims on the parties' separate, but judicially consolidated, petitions for review of two tax abatement decisions, holding that the court erred in partially abating a portion of certain penalties levied by the State Tax Assessor against Kraft.On appeal, Kraft argued that the lower court erred in determining that it was not entitled to an alternative apportionment of a portion of its 2010 taxable income, that it was not entitled to a full abatement of penalties levied by the Assessor as part of the "first assessment," and that the "second assessment" was not time barred. The Assessor cross-appealed, arguing that the lower court erred in partially abating the substantial understatement penalty levied as part of the first assessment. The Supreme Court (1) affirmed the court's conclusion that Kraft was not entitled to an alternative apportionment; (2) vacated the court's partial abatement of the substantial underpayment penalty because Kraft was not entitled to any abatement; and (3) affirmed the court's determination that the second assessment was not barred by the statute of limitations. View "State Tax Assessor v. Kraft Foods Group, Inc." on Justia Law

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The Supreme Judicial Court affirmed the judgment of the superior court concluding that the Department of Administrative and Financial Services (DAFS) had issued correct decisions regarding Somerset County's two requests for public records submitted pursuant to Maine's Freedom of Access Act (FOAA), Me. Rev. Stat. 1, 400-414, holding that the court properly concluded that one set of records was subject to disclosure and the other set was not subject to disclosure.In December 2016 and October 2017 the County submitted its requests seeking records concerning valuation information that Blue Sky West, LLC had submitted to Maine Revenue Services as part of the State's assessment of taxes on property that Blue Sky owned in the County. DAFS determined that the records responsive to the County's 2016 request were public records subject to disclosure but that the records responsive to the 2017 request were confidential by statute and thus were not public records. The Supreme Court affirmed, holding that the court did not err by concluding that the 2016 records were subject to inspection and copying by the public but that the 2017 records comprised clearly labeled proprietary information protected from disclosure pursuant to FOAA. View "Blue Sky West, LLC v. Maine Revenue Services" on Justia Law

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The Supreme Judicial Court affirmed the decision of the superior court granting summary judgment on Appellants’ appeal from the assessment of tax on certain foreign income, holding that there was no error in the proceedings below.On appeal, Appellants argued that the superior court misinterpreted and misapplied Me. Rev. Stat. 36, 5217-A regarding the income tax credit available to them for income taxes paid to a foreign jurisdiction and erred in determining that the penalties and interest assessed against them for the 2012 and 2013 tax years were appropriate. The Supreme Judicial Court affirmed, holding (1) the superior court properly upheld the decision limiting the credit available under section 5217-A; and (2) the court did not err in its decision to uphold in full the assessment of penalties and interest against Appellants. View "Warnquist v. State Tax Assessor" on Justia Law

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The Supreme Judicial Court held that an individual resident of Maine was not entitled to a Maine income tax credit for any portion of business taxes imposed by New Hampshire on a New Hampshire limited liability company of which the Maine resident was a member.Appellants, Maine residents, appealed from the judgment of the Business and Consumer Docket affirming the State Tax Assessor’s denial of a tax credit for a share of a New Hampshire business taxes paid by a New Hampshire LLC proportional to the membership interest that Appellants had in the LLC. The court reasoned that no income tax credit applied because (1) the New Hampshire business taxes were imposed on the LLC and were not an “amount of income tax imposed on [an] individual,” Me. Rev. Stat. 36, 5217-A; and (2) Maine’s tax statutes do not violate the Commerce Clause of the federal Constitution. The Supreme Judicial Court affirmed, holding (1) the lower court correctly interpreted Maine’s income tax statutes; and (2) the court did not err in concluding that Maine’s tax statutes are constitutionally sound. View "Goggin v. State Tax Assessor" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the State Board of Property Tax Review granting Emera Maine’s request for a property tax abatement for tax year 2012 pursuant to Me. Rev. Stat. 36, 841(1). Emera Maine was in the business of transporting and distributing electric power over transmission lines. The Board found that Emera’s abatement applications concerned an issue of error or illegality in assessment amounting to double taxation. The superior court affirmed the decision of the Board. The Supreme Judicial Court affirmed, holding that the evidence supported the Board’s finding that Emera’s error in estimating a value for and reporting ownership of a transmission line that Emera did not own resulted in an “illegality, error or irregularity in assessment” rather than an “error in the valuation of property,” thus entitling Emera to an abatement pursuant to Me. Rev. Stat. 36, 841(1). View "Town of Eddington v. Emera Maine" on Justia Law