Justia Tax Law Opinion Summaries

In 2008, Marlow Timberland (MT) filed a tax petition challenging the taxes payable in 2008 on the belief that Lake County's property tax assessment of MT's recently purchased land was too high. MT then filed tax petitions challenging the taxes payable in 2009 and 2010, which were dismissed due to MT's failure to pay the taxes. MT moved to reinstate the 2009 and 2010 petitions based on its contention that the properties were overassessed and that it was unable to pay the taxes due. The Minnesota Tax Court issued an order granting Lake County's motion to dismiss the 2008 petition and denying MT's motion to reinstate the 2009 and 2010 petitions. On review, the Supreme Court reversed in part and affirmed in part, holding (1) the tax court erred by not allowing MT to amend its 2008 petition because an amendment would not result in any prejudice to Lake County; and (2) the tax court properly denied MT's motion to reinstate its 2009 and 2010 tax petitions, and reinstatement of those petitions was not required on an equitable basis. Remanded.

Eden Prairie Mall (EPM) challenged the assessed value determinations of one of its anchor tenants. For the tax years 2005 and 2006, the court concluded that the market values of EPM and the tenant should have been assessed at higher rates than the assessments that were entered into evidence at trial. EPM argued that the tax court's valuations were excessive and not supported by the record. EPM filed for bankruptcy during the tax court proceedings and subsequently argued that the tax court violated the automatic stay provision of the bankruptcy code when the court increased its taxes. Upon review, the Supreme Court found that the tax court's reassessment did not violate the automatic stay of the bankruptcy code, but that the record did not support the reassessments. The Court reversed the tax court's holding, and remanded the case for further proceedings.