Action TV v. Board of Equalization
Annotate this Casepublication in the Pacific Reporter.
IN THE UTAH COURT OF APPEALS
----ooOoo----
Action TV, et al.,
Petitioner,
v.
County Board of Equalization
of Salt Lake County,
Respondent.
OPINION
(For Official Publication)
Case No. 981253-CA
F I L E D
July 29, 1999
1999 UT App 231
-----
Original Proceeding in Supreme Court
Attorneys:
Mark K. Buchi, Gary R. Thorup,
and Steven P. Young, Salt Lake City, for Petitioner
Mary Ellen Sloan and Michelle
Bush, Salt Lake City, for Respondent
-----
Before Judges Billings, Davis, and Orme.
ORME, Judge:
¶1
Action TV seeks review of
a final decision of the Utah State Tax Commission concluding, first, that
Action TV's rent-to-own personal property, unreported on its personal property
affidavits for the tax years 1989 through 1995, is "escaped property" subject
to a five-year retroactive assessment and, second, that the fair market
value of its rent-to-own personal property was properly estimated. We decline
to disturb the Commission's decision.
BACKGROUND
¶2
Action TV engages in a rent-to-own
business at three separate Utah locations, offering furniture, appliances,
and electronics to customers under rent-to-own contracts. Under these contracts,
Action TV customers receive possession of goods, typically for a rental
period of twelve to twenty-one months. If a customer faithfully makes payments
as required by the contract, at the end of the contract period he or she
will own the goods. Prior to that time, however, title to the property
remains with Action TV. If the customer elects to discontinue renting the
goods, he or she may return them at any time before the expiration of the
contract with--in the words of Action TV--"no further obligation." In such
an event, Action TV either rents the goods to another customer, sells them
outright, "junks" them, or donates them to charity.
¶3
For as long as it has been
in business, Action TV has timely filed all required tax reports and returns.
Nevertheless, for at least fourteen years, Action TV has failed to include
in its annual personal property affidavits any personal property subject
to rent-to-own contracts. Action TV's omission was originally based on
its belief that property in the possession of a rental customer was tax-exempt
as inventory held for sale in the ordinary course of business.
¶4
In May 1994, the Salt Lake
County Assessor audited Action TV for the six years from 1989 to 1994 and
assessed property taxes on rent-to-own property not reported in Action
TV's personal property affidavits during those years. A subsequent current-year
assessment was issued for 1995. The Assessor sought to tax Action TV for
all personal property held by its rental customers under rent-to-own contracts
on January 1 of each relevant tax year.
¶5
The tax assessments were
calculated using the cost approach, an estimate of fair market value based
on the wholesale cost Action TV paid to acquire the goods multiplied by
a depreciation factor reflecting the useful economic life of the property.
The Assessor relied on the Tax Commission's 1994 Recommended Schedules
for Personal Property Valuation and depreciated Action TV's rent-to-own
personal property according to the schedule for Class 3, five-year class
life property. Class 3 was selected based on the Assessor's judgment of
the useful economic life of the property. In 1994, the audit year, the
Commission's Recommended Personal Property Valuation Schedules defined
Class 3 personal property as "Short Life Trade Fixtures," "generally consist[ing]
of electronic types of equipment, includ[ing] property subject to rapid
functional and economic obsolescence or severe wear and tear." The most
pertinent example of Class 3 property given in the schedules was "Small
Equipment Rentals."
¶6
Action TV first appealed
all three tax assessments to the Salt Lake County Board of Equalization.
The Board affirmed the assessments, and Action TV appealed to the Utah
State Tax Commission. The Commission issued its Findings of Fact, Conclusions
of Law, and Final Decision on January 14, 1998, rejecting Action TV's arguments.
¶7
The Commission concluded
that rent-to-own property in the possession of Action TV's customers was
not exempt from taxation as inventory. The Commission determined that the
items of personal property omitted from Action TV's property tax affidavits
from 1989 to 1995 qualified as escaped property under Utah law. The Commission
also found that the Assessor properly valued the escaped property as Class
3, five-year class life property according to the Commission's Recommended
Schedules for Personal Property Valuation. Neither the Board nor the Commission
concluded that Action TV acted in bad faith or with intent to avoid its
tax obligations.
¶8
Action TV petitioned the
Utah Supreme Court for review of the Commission's decision. As permitted
by Utah Code Ann. § 78-2a-3(2)(j) (1996), the Supreme Court transferred
the case to this court for resolution.
ISSUES AND STANDARD OF REVIEW
¶9
Action TV presents two issues
for our review. First, Action TV argues it is improper to apply the escaped
property provisions, Utah Code Ann. §§ 59-2-102(8), -309(1) (1996
& Supp. 1998), to impose taxes on rent-to-own personal property omitted
from its personal property affidavits from 1989 through 1995. Second, Action
TV challenges the Commission's determination that the Assessor properly
calculated the tax on Action TV's rent-to-own personal property by applying
the Class 3, five-year class life depreciation schedule in accordance with
the Commission's 1994 Recommended Personal Property Valuation Schedules.(1)
¶10
The standard we apply "when
reviewing formal adjudicative proceedings commenced before the commission"
is governed by statute:
[T]he Court of Appeals
. . . shall . . . grant the commission deference concerning its written
findings of fact, applying a substantial evidence standard on review[,
but shall] grant the commission no deference concerning its conclusions
of law, applying a correction of error standard, unless there is an explicit
grant of discretion contained in a statute at issue before the appellate
court.
Utah Code Ann. § 59-1-610(1)
(1996).
¶11
"Whether property has escaped
assessment is a legal question[.]" First Sec. Mortgage Co. v. Salt Lake
County, 866 P.2d 1250, 1251 (Utah Ct. App. 1993). Accord County
Bd. of Equalization v. State Tax Comm'n ex rel. Sunkist Serv. Co.,
789 P.2d 291, 292 (Utah 1990); County Bd. of Equalization v. Nupetco
Assocs., 779 P.2d 1138, 1139 (Utah 1989). Further, the statutory sections
dealing with "escaped property," Utah Code Ann. §§ 59-2-102(8),
-217, -309 (1996 & Supp. 1998), contain no explicit grant of legislative
discretion to the Commission. Thus, in accordance with section 59-1-610,
we grant no deference to the Commission's conclusion that the rent-to-own
property at issue is escaped property but review it under a correction
of error standard. See id. § 59-1-610(1)(b).
¶12
In contrast, the Commission's
findings about the fair market value of Action TV's rent-to-own property
present questions of fact. See Alta Pac. Assocs. v. Utah State
Tax Comm'n, 931 P.2d 103, 109 (Utah 1997). The Commission is entitled
to deference on this issue "and [we] will overturn [its findings of fact]
only if the petitioner marshals the [evidence] and shows that in light
of the record as a whole, the [Commission's] findings are not supported
by substantial evidence." Hales Sand & Gravel, Inc. v. Audit Div.,
842 P.2d 887, 890 (Utah 1992). See Utah Code Ann. § 59-1-610(1)(a)
(1996).
I. CLASSIFICATION OF ACTION
TV'S RENT-TO-OWN
PROPERTY AS ESCAPED PROPERTY
¶13
Action TV challenges the
Commission's conclusion that its rent-to-own personal property is escaped
property subject to the five-year retroactive assessment permitted by Utah
law. "Escaped property" is defined as
Utah Code Ann. § 59-2-102(8)(a)(ii)
(Supp. 1998).(2) County assessors have discretionary
authority to assess escaped property "at any time as far back as five years
prior to the time of discovery." Id. § 59-2-309(1) (1996).
Accord id. § 59-2-217 (1996).
¶14
Action TV's position has
two facets.(3) First, Action TV argues that
its property, even if "subject to taxation," does not qualify as escaped
property because it was not "omitted from the tax rolls because of the
failure
of the taxpayer to comply with the reporting requirements." Utah Code Ann.
§ 59-2-102(8)(a)(ii)
(Supp. 1998) (emphasis added). Rather, it contends
that it could not "fail" to comply with the reporting requirements of the
Property Tax Act where the information available from the Commission concerning
taxation of rent-to-own property was unclear and inconsistent. Second,
Action TV argues that, inasmuch as it endeavored in good faith to comply
with the requirements of the Property Tax Act, it would be unfair to retroactively
subject it to an escaped property assessment.
¶15
Action TV based its nonpayment
of taxes on its interpretation of the tax exemption for inventory. That
exemption provides: "Tangible personal property present in Utah on the
assessment date, at noon, held for sale in the ordinary course of business
or for shipping to a final out-of-state destination within 12 months and
which constitutes the inventory of any retailer . . . is exempt from property
taxation." Utah Code Ann. § 59-2-1114(1) (Supp. 1998). Accord
Utah Const. art. XIII, § 2(4). Under Utah Code Ann. § 59-2-1114(3)(b)
(Supp. 1998), "'[i]nventory' means all items of tangible personal property
described as materials, containers, goods in process, finished goods, severed
minerals, and other personal property owned by or in the possession of
the person claiming the exemption." Focusing on one part of the statute's
definition of inventory--"personal property owned by or in the possession
of the person claiming the exemption"--Action TV concluded its rent-to-own
personal property, which it unquestionably owned though it did not possess,
was exempt inventory because the rented goods would eventually become sold
in the ordinary course of Action TV's business if the renter fully performed
the rental agreement. However, Action TV's theory ignored the more important
questions of whether it could fairly be regarded as a "retailer" and whether
eventual transfers of title at the conclusion of a long rental arrangement
could fairly be regarded as a "sale in the ordinary course of business."
Utah Code Ann. § 59-2-1114(1) (Supp. 1998).
¶16
According to the record
before us, the Commission first clearly indicated the inventory exemption
did not apply to rent-to-own property in its 1994 Recommended Schedules
for Personal Property Valuation. Even after the recommendation became a
rule in 1995, it continued to refer to a possible exemption for rent-to-own
property through 1996.(4) Compare
Utah Code Admin. P. R884-24P-33(C)(3) (1996) ("Property held for rent or
lease is taxable, and is not exempt as inventory. Entities engaged in .
. . rent-to-own may establish an exemption for inventory by filing form
TC-595[.]") with id. R884-24P-33(C)(3) (Supp. 1997) ("Property
held for rent or lease is taxable and is not exempt as inventory. For entities
primarily engaged in rent-to-own, inventory on hand at January 1 is exempt
and property out on rent-to-own contracts is taxable.")(5).
Action TV presented evidence to the Commission indicating confusion was
widespread in the rent-to-own industry concerning the taxation of personal
property under rent-to-own contracts. Indeed, the Commission specifically
found that "[d]uring the period in question rent-to-own businesses did
not uniformly report or value items of personal property on their personal
property affidavits."
¶17
For purposes of our decision,
we assume the uncertainty and confusion was as pervasive as Action TV would
have us believe. Nevertheless, we reject Action TV's argument that its
rent-to-own property cannot be "escaped property" because Action TV had
no way of knowing the property was assessable, and therefore could not
have failed to report it. First, Action TV places undue emphasis
on "fail" as used in the escaped property provision. We do not read the
provision as requiring some level of culpability. Our Legislature, while
providing that innocent underpayment of taxes could not be the basis for
assessing a penalty, see Utah Code Ann. § 59-1-401(5)(a) (1996),
has, for obvious reasons, not seen fit to condition tax liability on a
subjective realization that a tax was actually due.
¶18
Further, we find implausible
Action TV's theory that goods it rented and which were in customers' homes
were inventory it "held for sale in the ordinary course of business" as
a "retailer." Utah Code Ann. § 59-2-1114(1) (Supp. 1998). Although
Action TV may sell previously rented goods if they are returned or repossessed
before the contract is fulfilled, goods cannot be sold to ordinary retail
shoppers while in the homes of rental customers pursuant to rent-to-own
contracts.
¶19
Finally, the Utah Supreme
Court has held that, while a "negligence penalty is appropriate when .
. . a reasonable investigation into the applicable rules and statutes would
have revealed . . . the taxes were due," Hales Sand & Gravel, Inc.
v. Audit Division, 842 P.2d 887, 895 (Utah 1992), taxpayers can escape
penalties
if they "can show that [they] based the nonpayment of taxes on a legitimate,
good faith interpretation of an arguable point of law." Id. Of course,
the converse is also true: when a reasonable investigation into the applicable
rules and statutes would not have revealed taxes were due, the taxpayer
may avoid the negligence penalty--but in each instance the taxpayer remains
responsible to pay an escaped tax assessment if it is levied. Though the
Commission's rules did not explicitly inform Action TV that the inventory
exemption was inapplicable to its rent-to-own property until 1994, the
audit year, Action TV nevertheless must pay the escaped property assessment.
¶20
Action TV further argues
that, even if its rent-to-own property is "escaped property" under section
59-2-102(8), it is unfair and improper to apply the provision retroactively
because Action TV endeavored in good faith to comply with applicable tax
laws and guidelines. Again, Action TV's good faith would be relevant if
the Commission had assessed a penalty in addition to the escaped property
assessment. But a good-faith mistake in relying on the inventory exemption
does not preclude imposition of the basic escaped property assessment.
¶21
The Utah Supreme Court addressed
similar circumstances in Hales Sand & Gravel. The Court noted
that the statute at issue there "listing the sales tax exemptions presented
a potential ambiguity as to the scope of the exemption for intrastate movements
of freight, which may have misled Hales." 842 P.2d at 895. Hales's "nonpayment
of taxes [was therefore based] on a legitimate, good faith interpretation
of an arguable point of law." Id. But note the relief to which Hales
was therefore entitled: the Court reversed the negligence penalty assessed
against Hales, while affirming the sales tax deficiency assessment. See
id. Cf. Broadcast Int'l, Inc. v. Utah State Tax Comm'n,
882 P.2d 691, 696-98, 700-01 (Utah Ct. App. 1994) (upholding penalty where
interpretation of tax exemption for property purchased for resale was plausible
but was not "the basis for a carefully considered decision that no tax
was owed").
¶22
Similarly, in this case
the Tax Commission accepted that Action TV based its nonpayment of taxes
on a legitimate, good faith interpretation of the statutory language found
in section 59-2-1114 exempting inventory held for sale in the ordinary
course of business from tax liability. The Commission accordingly did not
impose the negligence penalty. While Action TV's good faith reliance on
a plausible interpretation of
the application of the statute might be persuasive
if Action TV were challenging the imposition of a negligence penalty, that
is not the issue before us. Action TV has not shown how, under existing
law, its reliance on an arguable point of law could do more than preclude
the assessment of a penalty against it. Action TV's reliance does not excuse
its responsibility to pay taxes on its escaped property.
II. VALUATION OF RENT-TO-OWN PROPERTY
¶23
We now consider Action TV's
argument that the Commission erred in upholding the Assessor's use of the
Commission's Class 3, five-year class life depreciation schedule to estimate
the fair market value of Action TV's rent-to-own personal property. The
Utah Constitution requires all tangible property in the state to be assessed
"according to its value in money." Utah Const. art. XIII, § 3. The
Legislature implemented this constitutional provision by requiring "[a]ll
tangible property [to] be assessed and taxed at a uniform and equal rate
on the basis of its fair market value." Utah Code Ann. § 59-2-103(1)
(1996). "Fair market value" is "the amount at which property would change
hands between a willing buyer and a willing seller, neither being under
any compulsion to buy or sell and both having reasonable knowledge of the
relevant facts." Id. § 59-2-102(9) (Supp. 1998).
¶24
Because individual appraisal
of every item of taxable personal property is not feasible, the Commission
has established personal property valuation schedules to estimate the fair
market value of personal property for tax purposes. The schedules employ
the cost approach, which estimates fair market value by depreciating the
wholesale or retail value of personal property according to an applicable
class life schedule. Class life schedules are tables prescribing the rate
at which personal property should be depreciated over time based on an
estimate of the property's useful economic life.
¶25
The Assessor used this approach
to estimate the fair market value of Action TV's taxable rent-to-own personal
property. The Assessor referred to Action TV's books to ascertain the wholesale
value of all items of personal property owned by Action TV and under rent-to-own
contracts on January 1 of each relevant tax year. He then depreciated the
wholesale value according to the Commission's Class 3, five-year class
life schedule, recommended for "short life trade fixtures" "subject to
rapid functional and economic obsolescence or severe wear and tear," such
as small equipment rentals. (6) Utah Code
Admin. P. R884-24P-33(C)(2) (1995). This calculation resulted in an estimated
fair market value reflecting both the property's original cost and its
expected useful economic life.
¶26
The Commission affirmed
the Assessor's application of the Class 3, five-year class life schedule.
(7) It appears the Commission considered
the five-year class life appropriate in part because it took into account
both the two to three years during which Action TV held title to the property
and a reasonable time thereafter during which the property ordinarily continued
to be used in the homes of former customers. It further appears the Commission
believed the five-year class life adequately reflected the shortened useful
economic life caused by unusual wear and tear common in rent-to-own property.(8)
¶27
The Commission found that
while Action TV "generally disposed of the items at issue within three
years of acquiring them, either through one or more rent to own contracts,
outright sales, or as a write off due to theft or poor condition," Action
TV's "[l]essee/customers . . . usually intended to keep the items for which
they entered into the rent-to-own contracts and they continued to use these
items after they acquired title from [Action TV]." Based on these findings,
the Commission concluded, "[t]he subject property is properly valued as
having a five year life by following the Recommended Schedules For Personal
Property Valuation promulgated by the Utah State Tax Commission."
¶28
Action TV challenges the
Assessor's application of the Class 3, five-year class life depreciation
schedule, arguing it overvalues Action TV's rent-to-own personal property.
Action TV asserts its rent-to-own personal property has only an eighteen-
to twenty-four-month useful economic life--not the sixty-month life used
by the Commission's valuation table. Action TV's witnesses testified, however,
that they estimated the useful economic life of the property based only
on the average length of time during which the property could be economically
sold or rented by Action. Eighteen to twenty-four months, therefore, reflected
only the useful economic life of the property to Action TV, not its fair
market value. Action TV's estimates did not include any continued useful
economic life to Action TV's successful rental customers.
¶29
The crux of Action TV's
challenge is its belief that in estimating useful economic life, it is
improper to consider the period of time after title to rent-to-own
property has passed to the customer.(9)
Thus, Action TV argued for a valuation based on a three-year depreciation
schedule. The Commission's Decision and Order expressly states it addressed
the question of whether "value [should] be based on a three year or a five
year class life." While the Commission's findings in this respect are not
a model of detailed clarity, they adequately support the Commission's conclusion
that a five-year, rather than a three-year, class life was "the proper
valuation method for the subject property."
¶30
Action TV claims application
of a class life longer than three years is error because the Commission
expressly found that Action TV "disposed" of its rent-to-own property within
three years.(10) Action TV argues
that the Commission, in selecting a useful economic life longer than three
years, impermissibly taxed Action TV on property it no longer owned and
that had become tax-exempt residential property in the homes of former
customers. Action TV is correct that its rent-to-own property becomes residential
property when title passes to a residential customer, and neither Action
TV nor its former customer can then be required to pay taxes on that property.
See Utah Code Ann. § 59-2-1113 (1996) ("Household furnishings,
furniture, and equipment used exclusively by the owner at the owner's place
of abode in maintaining a home for the owner and the owner's family are
exempt from property taxation."). Action TV, however, misconstrues the
role of estimated useful economic life in the fair market value calculation.
¶31
Action TV was assessed taxes
only on rent-to-own personal property under rent-to-own contracts on January
1 of each of the tax years at issue. It was not taxed on available property
not yet rented, or, if already rented and repossessed, not yet sold or
otherwise disposed of, which the Commission regarded as inventory. Nor
was Action TV taxed on personal property that, by the assessment date,
had become the property of a customer. The continued useful life of the
property in the homes of Action TV's former customers was considered solely
for its impact on the estimated fair market value of the property while
owned by Action TV. The statutory definition of "fair market value" establishes
an objective test. See id. § 59-2-102(9) (Supp. 1998). The
Assessor was required to estimate the fair market value of Action TV's
property in the abstract, not the value of the property from Action TV's
unique business perspective. Thus, although the Commission's five-year
class life schedule's estimate of the useful economic life of Action TV's
property took into account a period of time after title would pass to the
former renter, it did not result in a tax on property no longer owned by
Action TV.
¶32
The Commission's acceptance
of the five-year class life is supported by substantial evidence. Accordingly,
we reject Action TV's assertion that use of the Class 3, five-year class
life depreciation table overvalued its property. We therefore do not disturb
the Commission's rulings in this regard.
CONCLUSION
¶33
We see no error in the Commission's
conclusion that Action TV's rent-to-own personal property was escaped property
subject to a five-year retroactive tax assessment. We also see no error
in the Commission's finding that the fair market value of Action TV's rent-to-own
personal property was appropriately determined using the cost approach
depreciated according to the Commission's
Class 3, five-year class
life schedule. Accordingly, we have no occasion to disturb the Tax Commission's
order.
______________________________
Gregory K. Orme, Judge
-----
¶34
WE CONCUR:
______________________________
Judith M. Billings, Judge
______________________________
James Z. Davis, Judge
1. The Commission's 1994 Recommended Personal Property Valuation Schedules, with some minor changes, were eventually promulgated as actual rules, becoming effective February 13, 1995. See Utah Code Admin. P. R884-24P-33(C)(2) (1995).
2. As a convenience to the reader, and because the provisions in effect at the relevant times do not differ materially from the statutory provisions currently in effect, we cite to the most recent statutory codifications throughout this opinion, unless otherwise noted.
3. Action TV does not now directly challenge the Commission's ruling that Action TV's rent-to-own personal property was not exempt from taxation as inventory under Article XIII, section 2(4) of the Utah Constitution and Utah Code Ann. § 59-2-1114(1) (Supp. 1998).
4. Although
Action TV directs our attention to this inconsistency in the Commission's
regulations, it has not argued in the case before us, with the exception
of one response to a question posed at oral argument, that the Commission
should be constrained to apply its "change" in the rules only prospectively.
In circumstances similar to the instant case, the Commission has elected
to apply its decision only prospectively. See 49th Street Galleria
v. Tax Comm'n, 860 P.2d 996, 998 n.4
(Utah Ct. App. 1993) ("Because
of the conflicting advice provided by the Auditing Division, the Tax Commission
held that the Galleria would not be liable for the tax due on the roller
skating and batting cage receipts during the period of the audit, but only
prospectively."), cert. denied, 878 P.2d 1154 (Utah
1994). The Commission
did not elect to do so here. Nor, apparently, did Action TV request
such relief before the Commission. We therefore do not consider whether
it would be appropriate to require only prospective application of the
changes in the Commission's rules defining the tax status of rent-to-own
property.
5. The Supreme Court has held that "an agency may not take actions which '"conflict with [the] design of an Act, and when they do the court has a duty to invalidate them."'" Airport Hilton Ventures, Ltd. v. Utah State Tax Comm'n, 976 P.2d 1197, 1200 (Utah 1999) (citations omitted) (invalidating regulation assessing sales and transient room tax beyond scope of authorizing statute). Action TV, however, has not argued the Commission exceeded its authority when it promulgated the rule precluding rent-to-own establishments from claiming the statutory inventory exemption with respect to "property out on rent-to-own contracts."
6. When the schedules found their way into Commission rules in 1995, however, small equipment rentals were no longer mentioned in the examples of Class 3 Short Life Trade Fixtures. See Utah Code Admin. P. R884-24P-33(C)(2) (1995).
7. The schedule provided for rates of depreciation beginning with 84% the first year, 68% the second year, 51% the third year, 35% the fourth year, and 18% the fifth year.
8. The Commission's schedules assign a much longer useful economic life to some of the items Action rents and sells. Furniture, for instance, is listed in the Commission's schedules as Class 5 property, with a nine-year class life. See Utah Code Admin. P. R884-24P-33(C)(4) (1995).
9. The Commission found title to Action TV's property generally passed to a customer within three years, and, after title passed, much of the property continued to be used in the homes of former customers. Action TV presented evidence that its rent-to-own property sometimes had absolutely no economic value at the end of eighteen months to two years. Some of the property showed severe wear and tear and consequently was junked or donated to charity. Other property was stolen, for example, when customers moved and took rent-to-own items with them. Accordingly, the Commission found one of the ways Action TV "disposed" of its property was "as a write off due to theft or poor condition." However, the evidence showed only about 2% of Action TV's property suffered such a fate, while 65% of Action TV's rent-to-own customers fulfilled their rent-to-own contracts and became the owners of the property they had rented.
10. The County hearing officer who heard Action TV's appeal of the 1995 current-year tax assessment recommended to the Board of Equalization that Action TV's rent-to-own personal property be valued as Class 1, three-year class life property. According to the Commission's 1994 schedules, Class 1, "Short Life Property," depreciates at the rate of 70% the first year, 41% the second year, and 10% the third year. The Board rejected the hearing officer's recommendation and adopted the five-year depreciation method.
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