tax payment requirement (Idaho) · Go Syfert
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tax payment requirement in Idaho

11 Idaho opinions name it 2 courts 1973–2024 1 in the last five years

The cases below were cited by Idaho courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
Scott v. Gublergreen
idaho · 1973 · cited in 8 Idaho opinions naming this issue, 1979–2024
2 sentences

2011This Court returned to the tax payment requirement in Scott v. Gubler, 95 Idaho 441 , 511 P.2d 258 (1973).

2011This Court returned to the tax payment requirement in Scott v. Gubler, 95 Idaho 441 , 511 P.2d 258 (1973).

68
Flynn v. Allisongreen
idaho · 1976 · cited in 4 Idaho opinions naming this issue, 1981–2011
2 sentences

2011The adverse possessor’s payment of taxes on his actual acreage, payments which he reasonably believed covered the property he occupied, was sufficient to satisfy the tax payment requirement. 97 Idaho at 621 , 549 P.2d at 1068 .

2011The adverse possessor’s payment of taxes on his actual acreage, payments which he reasonably believed covered the property he occupied, was sufficient to satisfy the tax payment requirement. 97 Idaho at 621 , 549 P.2d at 1068 .

24
Roark v. Bentleygreen
idaho · 2004 · cited in 3 Idaho opinions naming this issue, 2004–2024
2 sentences

2004The lot number exception states: [I]n the case of boundary disputes between contiguous landowners, where one landowner can establish continuous open, notorious and hostile possession of an adjoining strip of his neighbor’s land, and taxes are assessed by lot number or by government survey designation, rather than by metes and bounds description, payment of taxes on the lot within which the disputed tract is enclosed satisfies the tax payment requirement of the ... statute.” Roark v. Bentley, 139 Idaho 793 , 86 P.3d 507 (2004) (citing Scott v. Gubler, 95 Idaho 441, 443-44 , 511 P.2d 258, 260-61

2004The lot number exception states: [I]n the case of boundary disputes between contiguous landowners, where one landowner can establish continuous open, notorious and hostile possession of an adjoining strip of his neighbor’s land, and taxes are assessed by lot number or by government survey designation, rather than by metes and bounds description, payment of taxes on the lot within which the disputed tract is enclosed satisfies the tax payment requirement of the ... statute.” Roark v. Bentley, 139 Idaho 793 , 86 P.3d 507 (2004) (citing Scott v. Gubler, 95 Idaho 441, 443-44 , 511 P.2d 258, 260-61

13
Wilson v. Gladishgreen
idahoctapp · 2004 · cited in 1 Idaho opinions naming this issue, 2011–2011
2 sentences

2011Under this rale, “the tax payment requirement will be satisfied if the adverse possessor occupies the same amount of land upon which he was taxed.” Wilson v. Gladish, 140 Idaho 861, 865-66 , 103 P.3d 474, 478-79 (2004) (citing White v. Boydstun, 91 Idaho 615 , 428 P.2d 747 (1967) and Flynn, 97 Idaho at 621 , 549 P.2d at 1068 ).

2011Under this rale, “the tax payment requirement will be satisfied if the adverse possessor occupies the same amount of land upon which he was taxed.” Wilson v. Gladish, 140 Idaho 861, 865-66 , 103 P.3d 474, 478-79 (2004) (citing White v. Boydstun, 91 Idaho 615 , 428 P.2d 747 (1967) and Flynn, 97 Idaho at 621 , 549 P.2d at 1068 ).

11
DeChambeau v. Estate of Smithgreen
idaho · 1999 · cited in 1 Idaho opinions naming this issue, 2005–2005
1 sentence

2005Indeed, when tax records are inconclusive, uncontradicted testimony that the adverse possessor paid taxes on the disputed property is sufficient to show compliance with the tax payment requirement, DeChambeau v. Estate of *273 Smith, 132 Idaho 568, 572, 976 P.2d 922, 926 (1999), and if both the record owner and adverse possessor pay taxes on the disputed property, the adverse possessor prevails.

11
Matter of Estate of Bagleygreen
idahoctapp · 1990 · cited in 1 Idaho opinions naming this issue, 2004–2004
2 sentences

2004See Matter of Estate of Bagley, 117 Idaho 1091, 1093 , 793 P.2d 1263, 1265 (Ct.App.1990) (appellate court can affirm trial court’s decision on theory different from theory applied by that court).

2004See Matter of Estate of Bagley, 117 Idaho 1091, 1093 , 793 P.2d 1263, 1265 (Ct.App.1990) (appellate court can affirm trial court’s decision on theory different from theory applied by that court).

11
Baxter v. Craneygreen
idaho · 2000 · cited in 1 Idaho opinions naming this issue, 2004–2004
2 sentences

2004The reason behind the lot number exception is that “when taxes are assessed according to some generic description, ‘it is impossible to determine from the tax assessment record the precise quantum of property being assessed.’ ” Baxter v. Craney, 135 Idaho 166, 171 , 16 P.3d 263, 268 (2000) (citing Flynn v. Allison, 97 Idaho at 621, 549 P.2d at 1068 ).

2004The reason behind the lot number exception is that “when taxes are assessed according to some generic description, ‘it is impossible to determine from the tax assessment record the precise quantum of property being assessed.’ ” Baxter v. Craney, 135 Idaho 166, 171 , 16 P.3d 263, 268 (2000) (citing Flynn v. Allison, 97 Idaho at 621, 549 P.2d at 1068 ).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Idaho. Read the followed side critically anyway.

Also cited on this issue (13)

CaseCitedYears
Trappett v. Davis green
idaho · 1981
2 sentences

2011As this Court warned in Trappett v. Davis, 102 Idaho 527 , 633 P.2d 592 (1981), though, “a good deal of the judicial gloss has evolved mechanically and without benefit of supporting rationale, a criticism which might well be leveled at the tax payment requirement itself.” Id. at 530 , 633 P.2d at 595 .

2011As this Court warned in Trappett v. Davis, 102 Idaho 527 , 633 P.2d 592 (1981), though, “a good deal of the judicial gloss has evolved mechanically and without benefit of supporting rationale, a criticism which might well be leveled at the tax payment requirement itself.” Id. at 530 , 633 P.2d at 595 .

52000–2011
White v. Boydstun green
idaho · 1967
2 sentences

2011In White v. Boydstun, 91 Idaho 615 , 428 P.2d 747 (1967), the Court considered the tax payment requirement.

2011In White v. Boydstun, 91 Idaho 615 , 428 P.2d 747 (1967), the Court considered the tax payment requirement.

32004–2011
Nasser v. Stahl green
indctapp · 1956
2 sentences

1973That court has held that in the case of boundary disputes between contiguous landowners, where one landowner can establish continuous open, notorious and hostile possession of an adjoining strip of his neighbor’s land, and taxes are assessed by lot number or by government survey desig *444 nation, rather than by metes and bounds description, payment of taxes on the lot within which the disputed tract is enclosed satisfies the tax payment requirement of the Indiana statute. 3 Nasser v. Stahl, 126 Ind.App. 709 , 134 N.E.2d 567 (1956); Echterling v. Kalvaitis, 235 Ind. 141 , 126 N.E. 2d 573 (1955

1973That court has held that in the case of boundary disputes between contiguous landowners, where one landowner can establish continuous open, notorious and hostile possession of an adjoining strip of his neighbor’s land, and taxes are assessed by lot number or by government survey desig *444 nation, rather than by metes and bounds description, payment of taxes on the lot within which the disputed tract is enclosed satisfies the tax payment requirement of the Indiana statute. 3 Nasser v. Stahl, 126 Ind.App. 709 , 134 N.E.2d 567 (1956); Echterling v. Kalvaitis, 235 Ind. 141 , 126 N.E. 2d 573 (1955

31973–1979
Echterling Et Ux. v. Kalvaitis Et Ux. green
ind · 1955
2 sentences

1973That court has held that in the case of boundary disputes between contiguous landowners, where one landowner can establish continuous open, notorious and hostile possession of an adjoining strip of his neighbor’s land, and taxes are assessed by lot number or by government survey desig *444 nation, rather than by metes and bounds description, payment of taxes on the lot within which the disputed tract is enclosed satisfies the tax payment requirement of the Indiana statute. 3 Nasser v. Stahl, 126 Ind.App. 709 , 134 N.E.2d 567 (1956); Echterling v. Kalvaitis, 235 Ind. 141 , 126 N.E. 2d 573 (1955

1973That court has held that in the case of boundary disputes between contiguous landowners, where one landowner can establish continuous open, notorious and hostile possession of an adjoining strip of his neighbor’s land, and taxes are assessed by lot number or by government survey desig *444 nation, rather than by metes and bounds description, payment of taxes on the lot within which the disputed tract is enclosed satisfies the tax payment requirement of the Indiana statute. 3 Nasser v. Stahl, 126 Ind.App. 709 , 134 N.E.2d 567 (1956); Echterling v. Kalvaitis, 235 Ind. 141 , 126 N.E. 2d 573 (1955

21973–1974
Swann v. Sweetwater Irrigation & Power Co. green
· 1908
2 sentences

1981White v. Boydstun, supra; Hogan v. Blakney, 73 Idaho 274 , 251 P.2d 209 (1952); Swank v. Sweetwater Irr. & Power Co., Ltd., 15 Idaho 353 , 98 P. 297 (1908).

1981White v. Boydstun, supra; Hogan v. Blakney, 73 Idaho 274 , 251 P.2d 209 (1952); Swank v. Sweetwater Irr. & Power Co., Ltd., 15 Idaho 353 , 98 P. 297 (1908).

11981–1981
Hogan v. Blakney green
idaho · 1952
2 sentences

1981White v. Boydstun, supra; Hogan v. Blakney, 73 Idaho 274 , 251 P.2d 209 (1952); Swank v. Sweetwater Irr. & Power Co., Ltd., 15 Idaho 353 , 98 P. 297 (1908).

1981White v. Boydstun, supra; Hogan v. Blakney, 73 Idaho 274 , 251 P.2d 209 (1952); Swank v. Sweetwater Irr. & Power Co., Ltd., 15 Idaho 353 , 98 P. 297 (1908).

11981–1981
Standall v. Teater green
idaho · 1974
2 sentences

1981The following cases apply the lot number corollary in one form or another: Nesbitt v. Wolfkiel, 100 Idaho 396 , 598 P.2d 1046 (1979); Standall v. Teater, 96 Idaho 152 , 525 P.2d 347 (1974); Scott v. Gubler, supra; Beneficial Life Ins.

1981The following cases apply the lot number corollary in one form or another: Nesbitt v. Wolfkiel, 100 Idaho 396 , 598 P.2d 1046 (1979); Standall v. Teater, 96 Idaho 152 , 525 P.2d 347 (1974); Scott v. Gubler, supra; Beneficial Life Ins.

11981–1981
Nesbitt v. Wolfkiel green
idaho · 1979
2 sentences

1981The following cases apply the lot number corollary in one form or another: Nesbitt v. Wolfkiel, 100 Idaho 396 , 598 P.2d 1046 (1979); Standall v. Teater, 96 Idaho 152 , 525 P.2d 347 (1974); Scott v. Gubler, supra; Beneficial Life Ins.

1981The following cases apply the lot number corollary in one form or another: Nesbitt v. Wolfkiel, 100 Idaho 396 , 598 P.2d 1046 (1979); Standall v. Teater, 96 Idaho 152 , 525 P.2d 347 (1974); Scott v. Gubler, supra; Beneficial Life Ins.

11981–1981
Fry v. Smith green
idaho · 1967
2 sentences

1973Fry v. Smith, 91 Idaho 740 , 430 P.2d 486 (1967) involved a fence which had been erected as a matter of convenience, not to mark a boundary, and a tax assessment description which included more than merely the government lot designation of the property in question.

1973Fry v. Smith, 91 Idaho 740 , 430 P.2d 486 (1967) involved a fence which had been erected as a matter of convenience, not to mark a boundary, and a tax assessment description which included more than merely the government lot designation of the property in question.

11973–1973
Townsend v. Koukol neutral
mont · 1966
2 sentences

1973E. g., Townsend v. Koukol, 148 Mont. 1 , 416 P.2d 532 (1966) ; Ernie v. Trinity Lutheran Church, 51 Cal.2d 702 , 336 P.2d 525 (1959).

1973E. g., Townsend v. Koukol, 148 Mont. 1 , 416 P.2d 532 (1966) ; Ernie v. Trinity Lutheran Church, 51 Cal.2d 702 , 336 P.2d 525 (1959).

11973–1973
Ernie v. Trinity Lutheran Church green
cal · 1959
2 sentences

1973E. g., Townsend v. Koukol, 148 Mont. 1 , 416 P.2d 532 (1966) ; Ernie v. Trinity Lutheran Church, 51 Cal.2d 702 , 336 P.2d 525 (1959).

1973E. g., Townsend v. Koukol, 148 Mont. 1 , 416 P.2d 532 (1966) ; Ernie v. Trinity Lutheran Church, 51 Cal.2d 702 , 336 P.2d 525 (1959).

11973–1973
Mulder v. Stands green
idaho · 1950
2 sentences

1973In Calkins v. Kousouros, supra, 72 Idaho at 156 , 237 P.2d at 1057 , a case involving a boundary dispute between the owners of city lots, where the adverse claimant’s lot was assessed as “Tax No. 3” this Court stated: “ Where a fence constitutes a monument between tracts of conterminous owners and such monument establishes the boundary line between the adjoining premises, the requirement of the statute as to payment of taxes is satisfied by such payment on the lot within which the disputed tract is enclosed * * * ’ Mulder v. Stands [ 71 Idaho 22, 26 , 225 P.2d 463 (1950)].” The rigid applicati

1973In Calkins v. Kousouros, supra, 72 Idaho at 156 , 237 P.2d at 1057 , a case involving a boundary dispute between the owners of city lots, where the adverse claimant’s lot was assessed as “Tax No. 3” this Court stated: “ Where a fence constitutes a monument between tracts of conterminous owners and such monument establishes the boundary line between the adjoining premises, the requirement of the statute as to payment of taxes is satisfied by such payment on the lot within which the disputed tract is enclosed * * * ’ Mulder v. Stands [ 71 Idaho 22, 26 , 225 P.2d 463 (1950)].” The rigid applicati

11973–1973
Calkins v. Kousouros green
idaho · 1951
2 sentences

1973In Calkins v. Kousouros, supra, 72 Idaho at 156 , 237 P.2d at 1057 , a case involving a boundary dispute between the owners of city lots, where the adverse claimant’s lot was assessed as “Tax No. 3” this Court stated: “ Where a fence constitutes a monument between tracts of conterminous owners and such monument establishes the boundary line between the adjoining premises, the requirement of the statute as to payment of taxes is satisfied by such payment on the lot within which the disputed tract is enclosed * * * ’ Mulder v. Stands [ 71 Idaho 22, 26 , 225 P.2d 463 (1950)].” The rigid applicati

1973In Calkins v. Kousouros, supra, 72 Idaho at 156 , 237 P.2d at 1057 , a case involving a boundary dispute between the owners of city lots, where the adverse claimant’s lot was assessed as “Tax No. 3” this Court stated: “ Where a fence constitutes a monument between tracts of conterminous owners and such monument establishes the boundary line between the adjoining premises, the requirement of the statute as to payment of taxes is satisfied by such payment on the lot within which the disputed tract is enclosed * * * ’ Mulder v. Stands [ 71 Idaho 22, 26 , 225 P.2d 463 (1950)].” The rigid applicati

11973–1973

Statutes the citing opinions construe

ID § Idaho Code § 5-210 (11) ID § Idaho Code § 12-121 (5) ID § Idaho Code § 5-207 (4) ID § Idaho Code § 5-209 (4) ID § Idaho Code § 12-120 (3) ID § Idaho Code § 5-208 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NJ 15 (1988–2022) ID 11 (1973–2024) IN 5 (1980–2019) CA 2 (2018–2018) MN 2 (1988–2024)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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