Canty v. Idaho State Tax Commission, 138 Idaho 178

Summary

The Idaho Supreme Court held that taxpayers were not entitled to credit Idaho tax liability for California alternative minimum taxes paid in a prior taxable year. The court also rejected increasing the tax basis of stock because of the California tax payment, reversed the district court, and remanded for recalculation of the tax.

Holdings

1. The Cantys were not entitled to claim Idaho credits in 1995 or 1996 for California alternative minimum tax paid in 1994. The statute limits the credit to tax payable to another state for the taxable year in which the Idaho credit is claimed.
2. The Cantys were not entitled to increase the basis of their Ventritex stock to its fair market value at the time of purchase based on the California alternative minimum tax payment.

Questions Presented

1. Whether Idaho Code section 63-3029 permitted the Cantys to claim Idaho credits in 1995 and 1996 for California alternative minimum tax paid in the 1994 taxable year.
2. Whether the Cantys were entitled to increase the basis of their Ventritex stock because they paid California alternative minimum tax on the stock-option exercise.
3. Whether the Tax Commission's interpretation of Idaho Code section 63-3029 was entitled to deference under the J.R. Simplot framework.

Disposition

reversed_and_remanded