North Carolina Underscores the Significance of Timely Compliance in Sales Tax Disputes

In the case of North Carolina Department of Revenue v. Hayden Olivia Bridal, LLC, the North Carolina Department of Revenue (the “DOR”) filed a Petition for Judicial Review against Hayden Olivia Bridal, LLC (the “Taxpayer”) concerning a tax assessment. The DOR sought to dismiss Taxpayer’s Petition for a Contested Tax Case Hearing on the grounds of untimeliness, invoking sovereign immunity. The Office of Administrative Hearings (OAH) initially denied the DOR’s motion to dismiss, prompting the DOR to seek relief in the Wake County Superior Court. After thorough review and consideration, the Court reversed the OAH’s decision and remanded the case, instructing the dismissal of Taxpayer’s Contested Case Petition. The Court determined that Taxpayer’s petition was untimely as it was filed after the statutory deadline, thus barred by sovereign immunity. Since the Contested Case Petition was emailed to the OAH Clerk after the Clerk’s office had closed on the day of the petition due date, it was deemed untimely filed. 26 N.C.A.C. 03.0102(e)(1) and 26 N.C.A.C. 03.0502(f) specify that when delivering by electronic mail, “documents sent after 5 pm are deemed sent at 8 am the following business day.”  The decision rested on the interpretation of statutory provisions governing the time limit for filing contested case petitions and the application of procedural rules. This ruling underscores the importance of adhering to statutory deadlines and procedural requirements in tax-related disputes, emphasizing the significance of timely compliance with filing procedures to maintain legal standing and ensure due process. Taxpayers must consider method of delivery for timely filing and whether the date sent or the date and time received is the acceptable standard for specified state deadlines, which may be tied to office hours. (North Carolina Department of Revenue v. Hayden Olivia Bridal, LLC, No. 23 CVS 10863, December 5, 2023)

Posted on May 13, 2024