Justia Utah Supreme Court Opinion Summaries

Utah's exemption statute provides that a retirement plan "that is described in" I.R.C. 401(a) is exempt from a debtor's bankruptcy estate. Upon filing for bankruptcy, Douglas Reinhart claimed that the funds in his Keogh retirement plan were exempt from bankruptcy proceedings. The bankruptcy court determined that the Keogh plan was not technically tax qualified under I.R.C. 401(a) due to certain operational defects. Although the Keogh plan was operationally in default, the bankruptcy court found the plan was described in section 401(a), and thus, the funds in the plan were exempt under the exemption statute. The bankruptcy court entered an exemption order, and the trustee of Reinhart's bankruptcy estate appealed. The U.S. district court affirmed. The Supreme Court accepted certification to answer the question of whether a retirement plan can be "described in" section 401(a) when it fails to fulfill that section's requirements for tax qualification. The Court held that a retirement plan is "described in" section 401(a) if it substantially complies with that section. View "Gladwell v. Reinhart" on Justia Law

Ivory Homes purchased various concrete products from a company that, when it delivered the products, provided an invoice that charged a single sales price without indicating separate delivery charges. Ivory Homes then discovered if it structured its transactions with the company differently and bargained for separate and independent delivery charges, the charges would not be taxable. Subsequently, Ivory Homes filed a refund request with the Utah Taxpayer Services Division for sales tax it paid for several years on expenses associated with the concrete products. The Division denied the refund. The Utah State Tax Commission also denied the refund request. The Supreme Court affirmed the Tax Commission's decision that it did not erroneously receive any tax and that Ivory Homes was not entitled to a tax refund where (1) under a substantial evidence standard of review, the Commission correctly made findings of fact that the parties did not intend delivery charges in their original transactions; and (2) alternatively, a plain language interpretation of the Refund Statute requires that the Tax Commission commit some error in its receipt of taxes before a taxpayer is entitled to a refund. View "Ivory Homes, Ltd. v. Utah Tax Comm'n " on Justia Law

Summit Water was a mutual water company providing culinary grade water to residential and commercial shareholders. After the Utah State Tax Commission audited Summit Water's annual property tax affidavit and concluded that the value of the distribution facilities was substantially higher than Summit Water reported that year, Summit County assessed Summit Water for the back taxes owed for the previous four years. In all, Summit County assessed Summit Water $204,020 in additional taxes. The Summit County Board of Equalization determined that Summit Water failed to establish that the taxation of the property was incorrect or illegal, concluding (1) Summit Water was not eligible for the constitutional tax exemption afforded to entities that own a water distribution system providing water for irrigating lands because the water used by Summit Water's shareholders was for nonagricultural purposes, and (2) there was no double taxation of Summit Water's property. The Commission affirmed. The district court reversed in part, holding that the constitutional exemption at issue includes any artificial watering of land, including nonagricultural properties. The Supreme Court affirmed, concluding that the constitutional exemption encompasses the nonagricultural watering of lands and that no double taxation occurred. View "Summit Water Distrib. Co. v. Utah State Tax Comm'n" on Justia Law

Several Utah counties appealed a tax court's valuation of T-Mobile's taxable Utah property, arguing the valuation did not give proper deference to the Commission's prior assessments, erroneously excluded the value of goodwill, and was based on inadmissible evidence. The Supreme Court affirmed, holding (1) the tax court correctly conducted a trial de novo under the standard of review; (2) the tax court properly excluded T-Mobile's accounting goodwill from its taxable Utah property because the Utah Constitution prohibits taxing goodwill as property; and (3) under the Utah rules of evidence, the tax court did not abuse its discretion when it determined T-Mobile's expert witness was a qualified expert and that his testimony was reliable. View "T-Mobile v. Tax Comm'n and Counties, et al." on Justia Law