Michael W. Gates and Susan J. Gates v. Larry Walther

Summary

The court reversed the grant of summary judgment to the Department of Finance and Administration because the Department failed to provide prima facie evidence establishing how it calculated the Gateses’ net taxable income and resulting tax liabilities for the relevant years. Although the record showed that the Gateses had some taxable income and had claimed personal expenses as business deductions, the Department did not identify which income and deductions produced its assessments, leaving a material factual dispute. The court remanded for further proceedings.