Untitled Texas Attorney General Opinion

EATFORNEYGENERAI. OFTEXAS Honorable George Ii.Sheppard Comptroller of Publi~cAccounts Austin, Texas Dear Sir: Opinion No. O-6195 Re: Whether~or not a claim for refund of the tax on motor fuel exported or lost by fire or other accident is subject to a six months limita- tion period for filing; whether' such six months limitation period in fire or other accident losses runs from the time of the delivery of the motor fuel'or from the date of the accident; and whether the Comptroller would be authorized to deduct from a current claim filed by an exporter, the amountof a former claim filed after safd six months period and paid in error. ~. In your letters of the 7th and 26th of September, 1944, you submit in substance the following questions: 1. Is a claim for a refund of the tax on motor fuel exported or lost by fire or other accident subject to 'the six months limitation period for filing? 2. If the answer is yes, does the six months llmita- tion period on fire or other accident losses run from the time of the delivery of the motor fuel or from the date of the accident. 3., If the six months limitati,,on period apolies in ex- port cases, would the Comptroller's Department be authorized to deduct from a current claim filed by an exporter the amount of a former claim filed after said six months period and paid in error by said Department? The motor fuel tax law is quite lengthy. Shorn of the verbiage unnecessary to a solution-of the problems here involved, Se'ction13 of said Act (Art. 7065b, Vernon's Annotated Civil Statutes), being the section dealing with refunds, provides as follows: Hon. George Ii.Sheppard, page 2 o-6195 "(a) Any person who'purchases motor fuel in the"State of Texas, and any distributor who appro- priates motor fuel~'foruse . . e for any purpose other than use in'a motor vehicle operated or in- tended to be operated in whole or in part upon any of'the public highways, roads, or streets of the State of Texas, on which'motor fuel tax has been paid, * . : shall be refunded the amount of such taxes o . m . . 0 '"(b) . . s No refund of'the tax shall be granted on any motor fuel to any person . . . un- less such motor fuel has been purchased from or used by a licensed refund dealer s . .; and the Comptroller .,, is hereby prohibited from issuing . . . . refund of the taxion any motor fuel notpur- chased from a licensed'refund dealer except refund ? on-'motorfuel exported,'lost by accident or pur- chased by the United States Government. "(c) An~invoice of exemption shall be demanded by the purchaser or recipient of motor fuelused for purposes, kid upon each delivery by a refund re’fund~ dealer, or upon each appropriation foruse of motor fuel . . *, an invoice of exemption shall be issued . . . . . . . "'(a) When a claimant purchases or acquires for use motor fuel upon which a refund of the tax may be due, he shall within six months from the date of delivery of the motor fuel . .;, and not thereafter, file with the Comptroller an affidavit. e . . . e "No refund shall be made where motor fuel is used later than six months from date of delivery 01" appropriation, and no refund shall ever be made where it appears from the Invoice, or from the af- fidavits, or other'evidence submitted, that the sale or delivery was made more thanksix (6) months prior to the date of filing of the application for refund. 1, e . . If any person shall export or lose~by fire or other accident any motor fuel in quantities of one hundred (100) gallons OP more, '. o . or shall sell motor fuel 0 . . to the United States G'overnment, for the exclusive use of sa'idGovernment, claim for refund of the 'tax so"paid may be made in'the manner herein nrovided, or as the Comotroller may direct. - . Hon. George H. Sheppard, page 3 o-6195 Providea,,further, that a bondea and licensed diitributor may, in lieu of filing claim for refund of the tax paid on motor fuel thereafter exported or sold to the united States Government for thenexclu- sive use of said Government, take credit on any monthly r@p’tiet’ and tax ‘paymentmade to the’COmptrOl- ler withln six’(6) months of the~date of said sale or exportation, for the amount of tax so paid. The Motor Fuel Tax Law contains an elaborate record and reporting system designed,to.‘preventtax evasion: Every person”’ engaged in the production, &WUfkctUre, refining, t??atiSPOrtatiDtI or’sale of motor fuel Ln Texas Is required to keep records as to motor fuel handled’by themeand to make reports to the comptroller concerning its possession and disposition, the purpose of these requirements being to gLve the Comptroller information as to every gallon of motor’fuel produced’in or’ imported into the State of Texas. This elaborate record system greatly assists ‘the Comptroller in collectFng the’tax, checking refund claims and preventing tax evasion and fraud. Obviously, ‘the passage of time makes the checking of, the motor fuel on a given date more difficult. Consequently, the Legislature saw fit in the~.abovestatutory provlsions to fFx the six months period of limitation, within which certain refund claims must be filed. The answer to ‘thefirst question turns upon a proper construction of the statutory provision that claim for refund incases of export accidental loss, or~‘salesto the United , States Government ‘may be made in the manner herein provided, or as the Comptroller may direct. I’ Section 23 of the Act’~‘in questYon gives the Compti?bller power to promulgate rules and regulations for the enforcement of the M-ctor Fuel Tax I&w ; We are”advised that no rule or regulation has been promulgated by your departmen? fixing.a time 1imLt within which.a claim’based on exports or accidental losses may be filed, if; indeed, you could Iawfully fix other than a six months limitation period’. Suffice it”to say that you havenot done so, and we.do not pass upon“your authorLty to do so, same not being necessary in reach- ing a decision In this opinion. I Refuhd claims on”exports and accidental losses, then, ai?& to “be made’In the manner herein provided,“’-We think this language shows a”legislative Intent that the balance of the’Act be looked to as’‘a pattern for filing requirements for such claims. We think the’words “In’the manner herein provided” imply a six months limitation ‘period0 Section 13 (d) of the Act, wherein these’words appear, is replete with the Mea of a SJx months. limitation period, the words “sfx (6) months” appearing in said Hon. George K. Sheppard, page 4 Q -6195 Section no less than five times. Our conclusion in the matter is further ~strengthenedin that the"Act provides (fourth para- graph of Section 13 d) that bonded snd licensed distributors, oh motor fuel exported or sold to the Un‘itedStates Government, may, 1n lieu offiling refund claims, take credit on their monthly report and tax payment "within s~ix(6) months-'ofthe date"of said~sale or exportation ~. . .' for the tax paid. It appea~rs'unreasonableto assume that the Legislature'infended to impose a six months limitation PerLod during which a d'istri- butor could collect a refund by listing St on hls~'reportaspan off&t against taxes he owed the State, and yet have'no such limitation on his direct application for'such refund. We'con- elude, therefore, that the Legislature In Its use of'the words "in the manner herein provided" Intended that the refund claims there'inreferred to should be subject to a six months limitation perlod for filing. The second question deals with the method of applica- tion of this rule In cases of motor fuel loss by fire or other accident. Again we must be guided by the pattern revealed in the remainder of the Act. A close analysis of~Sectlon 13 of the Act reveals that motor fuel tax refunds are authorized in five general situations as follows: (1) Sale by a licensed refund dealer to a purchaser for a non-highway use. (2) 'Yp;w;;a;;~;er for ,,non-highway use by a distributor licensed as a . (3) Exports. elusive 62: Sale to the United St ates Government for its ex- 0 (5) Loss by fire or other accident. In the first two cases mentloned, Section 13(c) of the Act requires that the refund dealer issue an invoice of'exemp- tion at the time of delivery OP at the time of appropriation, respectively, As we construe,the Statute, the six months period In the first situation, supra, begins to run at the time of delivery of the motor fuel to the purchaser; and in the second, the period begins with the appropriation, at which time the claimant "acquires for use" the motor fuel in question, receiv- ing, at the time he appropriates It, at least a constructive "delivery." Hon. George H. Sheppard, page 5 0 -6195 " In the third and fourth situations, supra;the fourth paragraph of Sectlon 13'(d)Provides that a bonded and licensed di.strLbutormay obtaln a refund 'onmotorfuel exported or sold to the Government by crediting same as an offset on his monthly report and tax payment "within six (6) months of the date of said sale or exportati'on."'We"have no difficulty in holding tha'tan affirmative clalm'for refund on motor fuel exported or sold to the Government must be filed within the same'tlme limit as the credit on the monthly report above referred to. In reviewing the picture as thus far made, we find that in each of the four situations, the claimant has a'full six months between the time he knows he will have's claim and the deadline for filing. A person whose only basis for refund is loss of'motor fuel by accident obtains his first knowledge oft, the existence of a situation in which the law allows a refund, at the time of the loss. He is not In a position to exercise any diligence with reference to the filing of a claim prior to that time. Accordingly, in keeping with the pattern setby'the Statute in'other refund situations, it is our oplnionthat a claimant has six months from the date of the accidental loss In which to file h1.sclaim rather than'from the date of'delivery. It is Immaterial under the statute as to when an exporter or a seller to the Government fir'stacqu'iredthe motor fuel. We think It likewise follows that the date of purchase br acquisi- tion by one who suffers loss by accrdent Is immaterial. '.Acon- trary holding would discriminate against the victims of adver- sity, and the statute reflects no such legislative intent. Question number three.presents a fact situation wherein a claim for refund, filed,by an exporter after the six months period, hasbeen paid." Our Opinlbn No. o-2765 discussed the payment of a refund claim which fafled~'tomeet statutory'.'require- ments'and'concluded that "asthe claimant has caused a warrant to Issue and be paid upon such claim, void by reason of his'own acts and omissions, he becomes indebted to the State of Texas for moneys improperly had and received from the Treasury of'the State',In the amount of such warrant . 0 . We think the same rule aDplies here and that said claimant becomes indebted to the State for the"amount of'such warrant. "Further, It is our opinion that in paying a current refund claim filed'by said exporter, your department may lawfully deduct the amount of this debt due the State, and Issue warrant for the difference. In so holding we~'arenot,unmindful of Article 4350, Re- vised Statutes, which reads: "No warrant shall be issued'to any person in-, debted to the State,"or to his agent, or assignee, untL1 such debt is paid." Hon. George H. Sheppard, page 6 o-6195 The rightsof the State to offset a debt due.it from a payment by the State to ttiedebtor, even after warrant for the full amount had issued, was upheld in the case of Citizens' State Rank v.~AmerIcanSurety Co., 65 S.W. (2d) 778, error re- fused. In that case, a sheriff filed claim with the State for fees Andyreceived a deficlehc'ywarrantwhich he endorsed to'the bank. Ttie'Comptrollerrefused to allow the warrant to be paid when It matured becau'sethe sheriff had collected certain~fees from the State which were unlawful, and the Comptroller "offset and deducted therefrom the amount of unlawful items. " The bank sued the sheriff and his surety. The Court held'that the surety was not liable. The Court said,: "The obligatfon of appellee, as surety, on the bond to pay'the State the unlawful'fees collected, ceas'edwhen the State collected such fees, which it was authorized to do, by deducting the amount thereof from the deficiency certifdcate theretofore issued to the sheriff." Judge S eer, in the case of Shannon'v. Ratcher, 299 S.W. 227 (Comm, App.P states the purpose of Article 4350 as follows: "The Statute was evidently passed in order that a person.might not receive money from the State when indebted to the State, and then, If said persons were lnsolve,nt,prevent the State from recovering the amount due it." It~is obvious that a withholding of'the‘amount of the debt tothe State such is contemplated in this case affords ample protection to the State and satisfies the intent of the Statute. Judge Alexander in the case of Thompson v. Prince, 126 S.W. (2d) 574, error'refiised,states: "In order'to authorize the offset of ohe claim against another, the demands must be." mutual. 0 . that is',they itiust be between the same parties and must be due in'the same capacity OP right;" We think the offset here involved complles"with these requirements, and with t'he further requirement that the demands in question be liquidated demands; Other authorities supporting out holding include; Rule 97, Texas Rules'of Civil Procedure; 57 C-J. 454; Wood v. N,Y,, 73 N.Y. 556; Price v. Lancaster CO., 24 Pa. Co. 225; 24 R.C.L. 813; Johnson v. City of Aberdeen, 266 Pac. 707 (Wash.). In order to avoid .misunderstanding,'wethink it appro- priateto mention that the'rule here enunciated d,oes,notwork both ways- A tax payer, on grounds of public policy, Is not permitted to offset a refund due him by the State agatnst his liability for taxes'owed to the State, in the absence of statu- State v, Humble Oil & Rfg. Co. 16g'S.W. (2d) ;o";"(~~~;""c';"~:. The Act only gives such statutory authority to a limited group, to-wit, bonded and licensed distributors on Hon. George H. Sheppard, page 7 0 -6195 claims based upon exports or sales to the United States Govern- ment. See fourth paragraph of Section 13(d). We trust this satisfactorily answers your inquiry. Yours very truly ATTORNEYGENERAL OF TEXAS By s/J. Arthur Siindlin J. Arthur Sandlin Assistant JAS:fo:wc BPPRUVED OCT 9, 1944 s/Carlos C. Ashley FIRST ASSISTANT ATTORNEY GENERAL Approved Opinion Committee By s/BWB Chairman