Justia Maine Supreme Court Opinion Summaries

Chadwick-BaRoss Inc., a business located in the City of Westbrook, is a heavy-equipment dealer that sells equipment at retail and occasionally leases equipment to customers. After receiving a 2012 personal property tax declaration from Chadwick-BaRoss, the City asked the company to include additional equipment that was held in the physical possession of others pursuant to lease agreements. Chadwick-BaRoss responded that those items were available for immediate sale and were therefore exempt from the personal property tax. When the City and its tax assessor (together, Defendants) issued a supplemental tax bill, Chadwick-BaRoss filed a complaint seeking a declaratory judgment that it did not owe personal property taxes on the equipment that it leased to others. The superior court entered summary judgment for Defendants, concluding that the equipment did not fall clearly within the personal property tax exemption for stock-in-trade. The Supreme Court affirmed, holding that the leased equipment was not held or kept in stock by Chadwick-BaRoss for sale or rental and was thus properly subject to taxation. View "Chadwick-BaRoss, Inc. v. City of Westbrook" on Justia Law

Plaintiff applied for abatement of real property taxes that the Town of Lebanon assessed against her property for the tax years 2011 through 2013. The Town denied the application on the basis that the taxes had been paid. After a de novo hearing, the York County Commissioners ultimately denied Plaintiff’s application for abatement for tax years 2011 and 2012 and remanded the matter for further action with respect to tax year 2013. The superior court affirmed the decision of the Commissioners with respect to the 2011 and 2012 tax years. The Supreme Judicial Court affirmed, holding that because Plaintiff failed to supply the Court with a complete and defined record of the evidence and arguments presented to the Commissioners, the Court could not review Plaintiff’s argument that the Commissioners were compelled to authorize an abatement. View "Penkul v. Town of Lebanon" on Justia Law

In 2010, the assessor for the Town of Scarborough valued Plaintiff’s property for the tax year 2010-11 at the same assessed value as set in 2005. Plaintiff subsequently filed an application for a tax abatement, which the assessor denied. Thereafter, Plaintiff filed an application for assessment review with Scarborough’s Board of Assessment Review, arguing that the Town’s assessor substantially overvalued his property. After a hearing, the Board denied Plaintiff’s appeal, concluding that Plaintiff did not meet his burden of showing that the property was substantially overvalued relative to its market value. The Supreme Court vacated the Board’s determination and remanded for a reevaluation of Plaintiff’s property, holding that, in this case, the evidence established that the property was substantially overvalued. View "Terfloth v. Town of Scarborough" on Justia Law

Plaintiff was a Maine-based law firm with affiliated law offices in other states. In an effort to determine the proper Maine income tax treatment for distributions to its New Hampshire partners, Plaintiff filed a Freedom of Access Act (Act) request with the Maine Revenue Service and the State Tax Assessor, ultimately seeking all allocation and apportionment formulas, methodologies, or calculations applicable to the determination of Maine income tax for nonresident partners in a partnership. The Revenue Service filed for in camera review of seven documents. After reviewing the documents in camera, the superior court determined that the documents were confidential and thus not subject to redaction or disclosure. The Supreme Court affirmed, holding that the documents that were covered by Plaintiff’s request for information consisted entirely of information deemed confidential pursuant to Me. Rev. Stat. Ann. 36, 191(1), which excepts certain tax information and records from the definition of public records pursuant to the Act. View "Preti Flaherty Beliveau & Pachios LLP v. State Tax Assessor" on Justia Law

Plaintiff was the administratrix of a Massachusetts estate appointed by a Massachusetts court. Part of the estate was a parcel of real property located in Maine that was later sold. The estate and the IRS agreed to value the back parcel at $950,000. Plaintiff later filed an amended Maine estate tax return, but insufficient funds remained in the estate to pay the Maine assessment. Plaintiff received a notice of assessment for Maine estate tax informing her that, as the estate's personal representative, she was personally liable for the money owed by the estate. Upon Plaintiff's request for reconsideration, the Assessor upheld an adjusted assessment of $98,180. The superior court vacated the Assessor's decision, concluding that the Assessor lacked jurisdiction to impose personal liability for unpaid estate taxes on a personal representative appointed by an out-of-state court to administer a foreign estate. The Supreme Court vacated the superior court's judgment and remanded for entry of judgment against Plaintiff, holding that Maine tax law provides the Assessor with the authority to hold a personal representative appointed by an out-of-state court personally liable for unpaid Maine estate taxes resulting from the sale of real property located in Maine. View "Metcalf v. State Tax Assessor" on Justia Law

Eagle Rental was a licensed used car dealer. Daniel Bickford and his wife were the company's vice president and treasurer. In 2003, Eagle Rental began purchasing Cadillac Escalades and trading them in to dealers for newer models. The Bickfords were unable to sell their Escalade inventory for several years and drove the Escalades on personal business. The tax assessor assessed use taxes on four of those Escalades. The business and consumer docket affirmed the assessment. Eagle Rental appealed, arguing it did not owe use tax because the Bickfords operated the Escalades with dealer plates for their personal use in accordance with Maine's dealer plate statute. Read together, the dealer plate and taxation statutes provide that dealers and their immediate families may use dealer plates on vehicles in a dealer's inventory for their personal use without being subject to use tax until the vehicles to which the plates are attached are withdrawn from inventory. The Supreme Court affirmed, holding that Eagle Rental did not meet its burden of proving that the Escalades were not withdrawn from inventory, and accordingly, the trial court correctly concluded they were subject to use tax. View "Eagle Rental, Inc. v. State Tax Assessor" on Justia Law

The Town of Madawaska foreclosed on Jeffrey and Jeanne Stoops' property after the Stoops failed to pay municipal taxes. The Town then conveyed the property to Richard and Betty Nelson by municipal quitclaim deed. The Stoopses subsequently filed a complaint against Richard Nelson seeking to quiet title to the property and asking the court to declare the respective rights of the parties to the property. The superior court granted the Nelsons' motion for summary judgment. The Stoopses appealed, arguing (1) the Town failed to give the Stoopses proper notice of the pending foreclosure in violation of their due process rights, and (2) the Town failed to adhere strictly to the requirements of the statutorily outlined steps a municipality must take to foreclose on a municipal tax lien. The Supreme Court affirmed, holding that because the Town complied with the requirements of the statutory scheme and gave the Stoopses sufficient notice, the trial court correctly granted summary judgment in favor of the Nelsons. View "Stoops v. Nelson" on Justia Law

In 2010, Hebron Academy requested a tax abatement from the Town for the 2009 tax year. Because the Academy did not file the abatement request before the statutory deadline, the Town denied the request. The Board of Assessment Review denied the request on the same ground. The Academy subsequently filed a complaint seeking a declaratory judgment that its properties were exempt from taxation and that the Town must reimburse it for real estate taxes it paid on its exempt properties for the prior three years. The superior court declared that the Academy was entitled to the exemption for most of its property but that res judicata precluded the court from relieving it of its obligation to pay the 2009 taxes at issue. The Supreme Court affirmed, holding (1) Hebron Academy, as a literary and scientific institution, was entitled to a tax exemption for its real estate "owned and occupied or used solely for [its] own purpose"; and (2) the trial court correctly concluded that res judicata precluded the declaratory judgment from applying to the 2009 tax year because an administrative adjudication had been rendered on the merits of the case. View "Hebron Academy, Inc. v. Town of Hebron" on Justia Law

Sears, Roebuck & Company appealed a judgment which concluded as a matter of law that the Supreme Court's holding in "Linnehan Leasing v. State Tax Assessor," (898 A.2d 408) applied retroactively. Sears argued that Maine recognizes the practice of retroactively applying certain legal holdings of a decision in a case to the parties in that case but only prospectively in all other instances. Sears urged the Supreme Court to adopt the three-part test enumerated in "Chevron Oil Co. v. Huson" (404 U.S. 97, 106-07 (1971)) when deciding whether to apply the holding of a decision retroactively to other cases. Sears further argued that "Linnehan Leasing" should not apply retroactively because the three Chevron factors weigh in favor of applying the holding with selective prospectivity. Finally, Sears argued that the Court should have reaffirmed its holding in "Myrick v. James" (444 A.2d 987, 1001-02 (Me. 1982)). Without addressing the issue of retroactivity, the Court applied the plain meaning of the statute at issue and affirmed. View "Sears, Roebuck & Company v. State Tax Assessor" on Justia Law

Victor Bravo Aviation, LLC purchased an aircraft in Connecticut in 2004 that was flown to Victor Bravo in Connecticut. Victor Bravo did not register the aircraft in Maine but used it regularly in Maine during the first twelve months of ownership. In 2007, the State Tax Assessor assessed Victor Bravo a use tax on its aircraft plus interest, penalties and costs. Victor Bravo appealed. The Business and Consumer Docket entered summary judgment for the Assessor affirming the assessment of the tax and interest, and judgment for Victor Bravo waiving and abating the non-payment penalty. The Supreme Court affirmed except vacated and remanded the issue of interest waiver or abatement. On remand, the court declined to waive or abate the interest as of the date of the reconsideration decision. Victor Bravo appealed. The Supreme Court affirmed, holding that the court properly considered Victor Bravo's arguments for failure to pay the use tax and deemed them unsatisfactory to warrant a waiver or abatement of interest under the statutory scheme. View "Victor Bravo Aviation, LLC v. State Tax Assessor" on Justia Law