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Green Mountain Carshare, Inc. v. Dep't of Motor Vehicles

Citation: Not availableDocket: 82

Court: Vermont Superior Court; March 16, 2015; Vermont; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In this case, Green Mountain Carshare, Inc., a non-profit organization, challenged a decision by the Vermont Department of Motor Vehicles (DMV) regarding the imposition of a use tax on rental cars. The central legal issue revolved around the interpretation of 32 V.S.A. § 8903, which imposes a use tax on rental vehicles but provides exemptions for vehicles owned by certain entities, including non-profits. The DMV had acknowledged CarShare's exemption from sales tax on vehicle purchases but maintained that the organization should collect use tax from customers renting its vehicles. The court, presided over by Judge Helen M. Toor, found that the statute's language was unambiguous in exempting vehicles owned by non-profits from the use tax, thereby reversing the DMV's decision. The court ruled that CarShare's ownership of the vehicles entitled it to the exemption, despite its operation as a rental service. This decision, issued on March 16, 2015, in Burlington, Vermont, underscores the statutory interpretation principle that tax exemptions must be strictly construed but acknowledged the clear statutory language in favor of the non-profit's exemption.

Legal Issues Addressed

Exemption from Use Tax under 32 V.S.A. § 8903

Application: The court determined that vehicles owned by non-profit organizations are exempt from the use tax on rental charges, irrespective of their use in rental transactions.

Reasoning: The court ruled in favor of CarShare, reversing the DMV's decision and confirming that the use tax does not apply to the vehicles owned by the organization.

Interpretation of Tax Exemption Statutes

Application: The court emphasized the principle that tax exemptions should be strictly construed against the claimant, but found the statutory language unambiguous in this case.

Reasoning: The court emphasized that tax exemptions should be strictly construed against the claimant. However, it found the statute's language unambiguous in stating that taxes do not apply to vehicles 'owned by' non-profits.