In the Matter of the Assessments for Tax Year 2012 of Certain Properties Owned by Clifton Throneberry and E. W. Crowe, Trustees of Pipeline Industry Benefit Fund and Local No. 798 Journeymen and Apprentices Plbg & Pipefitting v. John A. Wright, Tulsa County Assessor

Summary

The Oklahoma Supreme Court held that the general postjudgment-interest statute, 12 O.S. § 727.1, does not apply to a taxpayer's ad valorem tax protest appeal. Instead, interest on protested tax payments is governed exclusively by the specific ad valorem tax statute, 68 O.S. § 2884, which provides for investment of protested taxes and payment of accrued interest upon refund. The court reversed the district court's postjudgment-interest award and remanded for further proceedings.

Holdings

1. Taxpayers may not use 12 O.S. Supp. 2013 § 727.1 to obtain postjudgment interest on a refund arising from an ad valorem tax protest appeal when 68 O.S. Supp. 2015 § 2884 specifically governs interest on the protested tax payment.
2. The specific-controls-general canon applies because § 2884 affirmatively addresses interest on protested ad valorem taxes, while § 727.1 is a general judgment-interest provision.
3. Sanders does not authorize application of a general postjudgment-interest statute to an ad valorem tax protest appeal governed by § 2884 and is disapproved to that extent.

Questions Presented

1. Whether 12 O.S. § 727.1, the general postjudgment-interest statute, applies to a refund obtained through an ad valorem tax protest appeal.
2. Whether 68 O.S. § 2884 provides the exclusive procedure for calculating and paying interest on protested ad valorem tax payments.
3. Whether State ex rel. Oklahoma Employment Security Commission v. Sanders authorizes application of the general postjudgment-interest statute despite the specific ad valorem interest procedure in § 2884.

Disposition

reversed_and_remanded