Thompson Truck & Trailer, Inc. v. United States
Opinion
Thompson Truck & Trailer, Inc. (Thompson), appeals the dismissal of its complaint, arguing that the district court
1
erred in interpreting
Thompson is a semitruck dealership, whose principal offices are located in Cedar Rapids, Iowa. Thompson sells trucks equipped with diesel particulate filters (filters). The filters collect particulate matter from a truck's exhaust and turn it into a less harmful substance. Each filter increases a truck's retail sales price by approximately $8,000. Under Internal Revenue Code § 4051(a)(1), Thompson must pay a twelve percent excise tax on the trucks it sells. From April 1, 2011, to September 30, 2011, Thompson paid the excise tax on the full retail sales price of each truck sold, which included tax on the $8,000 value of each filter. On July 30, 2014, Thompson sought a refund of $387,840 from the Internal Revenue Service, arguing that-based on its interpretation of a federal regulation-the filters should not have been taxed. The Internal Revenue Service denied Thompson's claim.
We review "
de novo
the grant of a motion to dismiss, taking all facts alleged in the complaint as true."
Owen v. Gen. Motors Corp.
,
Thompson argues that the district court erred in its application of
Chevron, U.S.A., Inc. v. Natural Resources Defense Council, Inc.
,
Thompson argues that the district court erred at step one of the
Chevron
analysis by concluding that under
(a) Imposition of tax.-
(1) In general.- There is hereby imposed on the first retail sale of the following articles (including in each case parts or accessories sold on or in connection therewith or with the sale thereof) a tax of 12 percent of the amount for which the article is so sold:
(A) Automobile truck chassis.
(B) Automobile truck bodies.
(C) Truck trailer and semitrailer chassis.
(D) Truck trailer and semitrailer bodies.
(E) Tractors of the kind chiefly used for highway transportation in combination with a trailer or semitrailer. 2
Thompson claims that the phrase "parts or accessories" is ambiguous. We disagree. As we have stated previously, "[w]hen a word is not defined by statute," as is the case here, "we normally construe it in accord with its ordinary or natural meaning."
United States v. Jungers
,
We conclude that when the phrase "parts or accessories" is given its ordinary or natural meaning, the statute is not ambiguous and the filters fall within its scope. A "part" is "[a]ny of the manufactured objects that go to make up a machine or instrument, now esp. a motor vehicle; a component."
3
And an "accessory" is "[a] subordinate or auxiliary thing; an adjunct; an accompaniment; (now)
esp.
a minor fitting or attachment."
4
Applying these definitions, we conclude that the filters are parts or accessories of the trucks sold by Thompson because they are components of the trucks or minor fittings or attachments included with the trucks. This interpretation of § 4051(a)(1) is consistent with the provisions of the Internal Revenue Code as a whole. For example, § 4053 exempts specific items from taxation such as camper coach bodies for self-propelled mobile homes; feed, seed, and fertilizer equipment; house trailers; ambulances and hearses; concrete mixers; trash containers; mobile machinery; and idling reduction devices.
Thompson argues that such an interpretation of "parts or accessories" is inconsistent with
Mayo
, in which the Supreme Court held that the term "student" was ambiguous under the Federal Insurance Contributions Act when applied to medical residents who took classes and worked full time.
Given our decision under step one of the Chevron analysis, we do not consider Thompson's arguments regarding the federal regulations.
The judgment is affirmed.
The Honorable Linda R. Reade, United States District Judge for the Northern District of Iowa.
The origins of the statute date back to the War Revenue Act of 1917, Pub. L. No. 65-50 § 600(a),
Part, n.I.8, Oxford English Dictionary Online, http://www.oed.com/view/Entry/138188?result=1&rskey=mY2H5h& (last visited July 30, 2018).
Accessory, n.A.2.a, Oxford English Dictionary Online, http://www.oed.com/view/Entry/1046?redirectedFrom=accessory#eid (last visited July 30, 2018).
Reference
- Full Case Name
- THOMPSON TRUCK & TRAILER, INC., Plaintiff - Appellant v. UNITED STATES of America, Defendant - Appellee
- Cited By
- 5 cases
- Status
- Published