State v. Aisin USA Mfg., Inc.
946 N.E.2d 1148
| Ind. | 2011Background
- Zoeller sought recovery of an erroneously issued tax refund of about $1.15 million from Aisin in Jackson Superior Court.
- Aisin had paid its 2001 tax liability in full and later corrections produced a large refund error due to accounting/clerical mistakes in the Department’s systems.
- The Department issued the $1,146,062 refund based on miscalculations, not on misinterpretation of tax law.
- Aisin amended its 2001 return; the Department later cancelled a proposed assessment after discovering the errors, and sought recovery from Aisin.
- The State alleged unjust enrichment and related claims; Aisin moved to dismiss for lack of jurisdiction and for failure to state a claim; trial court granted dismissal for lack of Tax Court jurisdiction; Court of Appeals affirmed.
- The Supreme Court granted transfer to resolve whether the case arose under Indiana tax law and thus belonged in the Tax Court or could proceed in Superior Court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Jackson Superior Court has subject matter jurisdiction. | Zoeller argues Tax Court has exclusive jurisdiction. | Aisin contends it does not arise under tax law; jurisdiction is proper in Superior Court. | Jackson Superior Court has jurisdiction; case does not arise under tax law. |
| Whether the case principally involves collection of a tax or defenses to collection. | State asserts collection-related issues arise under tax law. | Aisin argues accounting errors and restitution do not implicate tax collection. | The case does not principally involve the collection of a tax or defenses to collection. |
| Whether the State may pursue restitution for an erroneously issued refund as a common-law claim. | State may seek restitution for unjust enrichment. | Aisin argues statutory assessment remedies govern; limitations bar restitution. | Common-law restitution is available; assessment remedies do not apply to this erroneous refund. |
| Whether the refund constitutes a final assessment or falls outside limitations. | Not applicable to Tax Court jurisdiction; limitations do not foreclose the restitution claim. |
Key Cases Cited
- State v. Sproles, 672 N.E.2d 1353 (Ind. 1996) (defines "arises under" in Tax Court jurisdiction)
- Lake Superior Court, 820 N.E.2d 1247 (Ind. 2005) (challenges to tax assessments arise under tax law)
- Ispat Inland, Inc., 784 N.E.2d 477 (Ind. 2003) (challenge to tax collection or assessment involves tax law)
- Montgomery, 730 N.E.2d 680 (Ind. 2000) (challenge to collection of a tax falls within Tax Court jurisdiction)
- Costa, 732 N.E.2d 1224 (Ind. 2000) (tax-law interpretation needed; tax court jurisdiction)