Warehouse Market Inc. v. State of Oklahoma ex rel. Oklahoma Tax Commission

Summary

The Oklahoma Supreme Court held that Warehouse Market's interpleader action was substantively a tax protest after the Muscogee (Creek) Nation Tax Commission was dismissed on sovereign-immunity grounds. Because exhaustion of administrative remedies is a jurisdictional prerequisite to judicial relief from a tax assessment, the Court reversed and remanded with instructions to dismiss the action and transfer the deposited sales-tax funds to the Oklahoma Tax Commission, subject to statutory fees.

Holdings

1. After the Tribal Tax Commission was dismissed on sovereign-immunity grounds, Warehouse Market's action was no longer a proper interpleader and became substantively a tax protest because it challenged the OTC's authority to impose and collect sales tax.
2. A taxpayer challenging an Oklahoma Tax Commission assessment must exhaust the prescribed administrative remedies before seeking relief in the district court, and exhaustion is a jurisdictional prerequisite.
3. The district court must dismiss the action and transfer the state sales-tax funds deposited with the court clerk to the Oklahoma Tax Commission, subject to statutory poundage and other appropriate fees.

Questions Presented

1. Whether Warehouse Market's action, initially styled as an interpleader, was substantively a tax protest after the Muscogee (Creek) Nation Tax Commission was dismissed on sovereign-immunity grounds.
2. Whether exhaustion of administrative remedies is a jurisdictional prerequisite to judicial relief from an Oklahoma Tax Commission sales-tax assessment.
3. Whether the district court should dismiss the action and transfer the deposited state sales-tax funds to the Oklahoma Tax Commission.

Disposition

reversed_and_remanded