STATE OF WISCONSIN
TAX APPEALS
COMMISSION
KRISTIAN L. AND JUSTINA R. HARNAGE, DOCKET NO.
19-I-159
Petitioners,
vs.
WISCONSIN DEPARTMENT OF REVENUE,
Respondent.
RULING AND ORDER
DAVID L. COON, COMMISSIONER:
This
matter come before the Commission for decision on a Motion for Summary Judgment
filed by the Wisconsin Department of Revenue (“the Department”). The
Petitioners, Kristian L. and Justina R. Harnage, Trempealeau, Wisconsin, appear
pro se. The Department is represented by Attorney Sheree Robertson. The
parties filed a Stipulation of Facts. The Department filed a brief and
affidavit in support of its position. The Petitioners filed a letter stating
that the facts in the Stipulation are correct and declining to file further
briefing or other supporting documentation in response to the Motion for
Summary Judgment. For the reasons stated below, we find for the Department.
FACTS
1.
Petitioner, Kristian L. Harnage, is a United
States Military Veteran having served from April 19, 1994, to November 8, 2001.
(Stipulation of Facts (“Stip.”) ¶ 7.)
2.
In 2012, Mr. Harnage submitted a Veteran's
Application for Increased Compensation Based on Unemployability to the United
States Department of Veterans Affairs (“VA”), beginning a process to be
declared disabled due to service-connected disabilities. (Stip.
¶ 8, Ex. 4.)
3.
Six years after beginning the process, in a
letter to Mr. Harnage dated September 18, 2018, which is a summary of benefits,
the VA states that Mr. Harnage was determined to be totally and permanently
disabled due to his service-connected disabilities as of July 1, 2012. (Stip. ¶ 10, Ex. 4.)
4.
The VA’s September 18, 2018 letter was
provided for Mr. Harnage to use in applying for benefits such as state or local
property or vehicle tax relief, civil service preference, to obtain housing
entitlements, free or reduced state park annual memberships, or any other
program or entitlement in which verification of VA benefits is required. (Stip.
¶ 10, Ex. 4.)
5.
Petitioners filed amended 2012 and 2013
Wisconsin income tax returns on November 5, 2018, claiming the Eligible
Veterans and Surviving Spouse Property Tax Credit (“Credit”). (Stip. ¶ 1.)
6.
Based upon the original unextended
due dates for the 2012 and 2013 Wisconsin tax returns, the last day for
Petitioners to file an amended 2012 Wisconsin income tax return to make a valid
claim was April 18, 2017, and the last day for them to file an amended 2013 Wisconsin
income tax return to make a valid claim was April 18, 2018. (Stip. ¶ 1, Ex. 1.)
7.
The Department issued to Petitioners a Notice,
dated November 28, 2018, denying the $3,690 refund claimed on their amended
2012 Wisconsin income tax return, and denying the $1,765 refund claimed on
their amended 2013 Wisconsin income tax return because the amended returns making
the claims were filed more than four years after the original due date. (Stip.
¶ 1, Ex. 1.)
8.
Petitioners timely filed a Petition for
Redetermination. (Stip. ¶ 2, Ex. 2.)
9.
The Department of Revenue wrote a letter to
Petitioners dated February 14, 2019, explaining that their claims for
refund were disallowed because they were filed more than four years after the
original due date, referencing Wis. Stat. § 71.75(2). (Stip. ¶ 14, Ex. 7.)
10.
The Department issued to Petitioners a Notice
of Action, dated March 13, 2019, denying their Petition for Redetermination.
(Stip. ¶ 3, Ex. 3.)
11.
Petitioners timely filed a Petition for
Review with the Commission. (Commission File.)
12.
On November 22, 2019, the parties filed a Stipulation
of Facts with the Commission. (Commission File.)
13.
On December 30, 2019, the Department filed a Motion
for Summary Judgment along with a brief and affidavit. On March 13, 2020, the
Petitioners filed a letter stating that the Stipulation of Facts accurately set
forth the matter and that they would be filing no brief or additional
information. (Commission File.)
applicable law
Statutes
Wis. Stat. § 71.07(6e)(b): Filing claims. Subject to the
limitations provided in this subsection, a claimant may claim as a credit
against the tax imposed under s. 71.02 the amount of the claimant's
property taxes. If the allowable amount of the claim exceeds the income taxes
otherwise due on the claimant's income, the amount of the claim not used as an
offset against those taxes shall be certified by the department of revenue to
the department of administration for payment to the claimant by check, share
draft, or other draft from the appropriation under s. 20.835 (2) (em).
Wis. Stat. § 71.07(6e)(c)1.:
No
credit may be allowed under this subsection unless it is claimed within the
time period under s. 71.75 (2).
Wis. Stat. § 71.75(2): With respect to
income taxes and franchise taxes…refunds may be made if the claim therefor is
filed within 4 years of the unextended date under
this section on which the tax return was due.
Summary Judgment
Summary
judgment is granted if the pleadings, depositions, answers to
interrogatories, and admissions on file, together with affidavits, show there
is no genuine issue as to any material fact and that the moving party is
entitled to judgment as a matter of law. Wis. Stat. § 802.08(2). Here, the
parties have stipulated to the material facts and determination of the matter
on summary judgment is appropriate.
DECISION
Eligible
veterans may claim a Credit under Wis. Stat. § 71.07(6e)(b).
Per Wis. Stat. § 71.07(6e)(c)1., one of the requirements to receive the Credit is that
"No credit may be allowed under this subsection unless it is claimed
within the time period under s. 71.75(2).” Therefore, the claim for the Credit
must be made within the time specified in Wis. Stat. § 71.75(2),
which states, in part, that "refunds may be made if the claim therefor is
filed within 4 years of the unextended date under
this section on which the tax return was due."
In
this matter, Petitioners have stipulated that the last day to file an amended 2012
Wisconsin income tax return to make a valid claim was April 18, 2017, and the
last day to file an amended 2013 Wisconsin income tax return to make a valid
claim was April 18, 2018. Petitioners’ amended
2012 and amended 2013 Wisconsin income tax returns were filed on November 5,
2018, well beyond the deadline specified in Wis. Stat. § 71.75(2). The claims
were not made within four years of the unextended
date on which the tax returns were due.
Therefore, based upon the stipulated facts, as a matter of law, the
Department of Revenue is entitled to Summary Judgment because claims for the
Credit for 2012 and 2013 were not timely. Even if the Petitioners meet all
other requirements for the Credit, the claims were not filed within the
statutory time period set forth in Wis. Stat. § 71.75(2).
For
the Petitioners, it was a long and, no doubt, frustrating quest before the VA to
show that Mr. Harnage had a service-connected disability. If the Commission had
equitable powers to determine matters based upon “fairness,” the Commission
might well be inclined to exercise that power here. However, “the legislature
has empowered this agency to determine and apply Wisconsin tax statutes, but not
to preempt application of a statute under a doctrine of equity.” Peterson
v. Dep't of Revenue, Wis. Tax Rptr. (CCH)
¶203-026 (WTAC 1989) (citations omitted).
While
it will not help the Petitioners at this point, the Department does outline in
its Brief what the Petitioners could have done to preserve their right to make
a claim for the Credit while awaiting VA action. The Department states,
Petitioners “could have timely filed Wisconsin income tax returns [or timely
filed amended returns] claiming the Veterans Credit and further could have
asked the Department of Revenue not to act on any claims for refund until the
federal Department of Veterans Affairs issued a final decision on…appeal.” At a
minimum, this shows that there may be ways for veterans waiting for VA
disability determinations to work with the Department to preserve their rights.
Every tax situation may be different based upon the particular fact situation,
so veterans, who are in the process of making a disability claim, should
contact the Department to request assistance with this process to preserve
their rights to claim the Credit during what could be a prolonged proceeding
with the VA. The Commission hopes that Wisconsin Department of Veterans Affairs
and any other organizations working with veterans will take note of the
Department’s willingness to work with veterans and assist them accordingly.
CONCLUSIONS OF LAW
The
Petitioners’ claims for the Credit were untimely under Wis. Stat. § 71.07(6e)(c)1. and Wis. Stat. § 71.75(2); therefore, the Department
properly denied the claim.
ORDER
The
Respondent’s Motion for Summary Judgment is granted, and the Petitioners’
Petition for Review is dismissed.
Dated at
Madison, Wisconsin, this 27th day of April, 2020.
WISCONSIN TAX APPEALS
COMMISSION
Elizabeth Kessler,
Chair
Lorna Hemp Boll,
Commissioner
David L. Coon, Commissioner
ATTACHMENT: NOTICE OF APPEAL INFORMATION