Justia Tax Law Opinion Summaries

After Washington County assessed the value of one of properties owned by Kohl's Department Stores for the years 2007-2009, Kohl's challenged the valuation. The tax court adjusted the County's assessment by increasing the valuations for 2007 and 2008 and decreasing the valuation for 2009. The Supreme Court affirmed, holding the tax court not err (1) by failing to adjust its capitalization rate to account for the property taxes paid by the owner on vacant space and for the neighborhood's excessive vacancy; and (2) when it calculated the property's fair market rent using comparable leases rather than a percentage of retail sales method. View "Kohl's Dep't Stores, Inc. v. County of Washington" on Justia Law

The Commissioner of Revenue ordered Sharon Soyka to pay income taxes, penalties, and interest for the 2007 tax year. Soyka had sixty days to appeal the Commissioner's order to the tax court. Instead, Soyka filed her notice of appeal to the Commissioner, who forwarded the documents to the tax court. The tax court dismissed Soyka's appeal as untimely filed because Soyka did not file her notice of appeal until more than a month after it was due and because Soyka did not file a request seeking an extension of time. The Supreme Court affirmed the tax court's dismissal of Soyka's appeal, holding (1) Soyka's failure to file her notice of appeal before the expiration of the statutory deadline deprived the tax court of subject matter jurisdiction over the appeal; and (2) because the tax court did not receive a copy of Soyka's extension request until the statutory period had expired, Soyka was not entitled to an extension of time to file her appeal. View "Soyka v. Comm'r of Revenue" on Justia Law

Taxpayer was a trust fund that purchased property in Ramsey County. Taxpayer sought an exemption from taxation for the property on the basis that it was a "seminary of learning" and therefore exempt under Minn. Stat. 272.02(5). The County allowed an exemption for several years but later determined that the property was no longer exempt and assessed the property. Taxpayer subsequently filed a petition challenging the assessment. After the tax court denied Taxpayer's motion to amend or supplement its petition, Taxpayer sought certiorari review. The Supreme Court dismissed the writ of certiorari, holding that it lacked jurisdiction because the tax court's order was not reviewable either as a final order under Minn. Stat 271.10 or in the interests of justice under Minn. R. App. P. 105.01. View "Metro. Sheet Metal Journeyman & Apprentice Training Trust Fund v. County of Ramsey" on Justia Law

In 2005, the Department of Revenue audited Relator and assessed Relator for the amount of sales tax he collected from his customers but failed to remit to the State. The Commissioner of Revenue (Commissioner) adjusted the initial assessment and assessed tax. The tax court upheld the Commissioner's assessment. The Supreme Court affirmed. In 2011, Plaintiff submitted to the Commissioner documents and an informal request for a refund based on his repayment of sales tax to his customers. The Commissioner responded to Relator by letter, in which he denied Plaintiff's request for a refund. Plaintiff appealed to the tax court. The tax court concluded it lacked subject matter over the appeal, holding that the Commissioner's letter was not an appealable order of the Commissioner because it was merely administrative correspondence. However, the court also denied Relator's claim for a refund. The Supreme Court (1) reversed the tax court's decision as to its jurisdiction, holding that the Commissioner's consideration of Relator's refund claim was a final decision on the claim that could be appealed; and (2) affirmed the tax court's decision on the merits of Relator's refund claim, holding that Relator's arguments either lacked merit or were barred by res judicata. View "Schober v. Comm'r of Revenue" on Justia Law

Plaintiff and his ex-wife both claimed their two children as dependents on their state individual income tax returns. The Minnesota Department of Revenue determined that only Plaintiff's ex-wife was entitled to claim the children as dependents and that Plaintiff had underpaid his state taxes. Plaintiff appealed. The extended deadline for filing Plaintiff's notice of appeal was December 27. On December 22, Plaintiff mailed his notice of appeal to the tax court and the Department of Revenue. The Department received the notice on December 27, but the notice sent to the court was marked by the court as filed on December 28. The The tax court dismissed Plaintiff's appeal for lack of subject matter jurisdiction on the ground that Plaintiff had not timely filed his notice of appeal. The Supreme Court affirmed, holding (1) the mailbox rule does not extend to statutorily created rights of appeal; and (2) Plaintiff failed to present direct evidence in support of his assertion that his notice of appeal arrived on December 27. View "Harbaugh v. Comm'r of Revenue" on Justia Law

The Living Word Bible Camp, a tax-exempt organization, owned property in Itasca County. Living Word sought to obtain the necessary governmental approvals to use the property as a summer bible camp and retreat center. Itasca County classified the property as tax-exempt from 2001 to 2007 then reclassified the property as taxable as of 2008. Living Word challenged the reclassification for the 2008 and 2009 assessments. The tax court affirmed the County's reclassification because Living Word had failed to make sufficient progress in obtaining the necessary governmental approvals for its proposed use of the property. The Supreme Court reversed, holding that the tax court (1) erred in concluding that Living Word was not entitled to an exemption because it was not using the property in furtherance of a charitable purpose; and (2) erred in determining that Living Word's current activities on the property could not be considered in determining whether that use was sufficient to qualify as a tax-exempt use. Remanded. View "Living Word Bible Camp v. County of Itasca" on Justia Law

Eden Prairie Mall, LLC (EPM) owned a mall. Included in the mall parcel for property tax purposes were the mall's in-line tenants, five anchor tenants, and a movie theater complex. EPM sought review of the tax court's market value determinations for the mall and one of its anchor tenants for the assessment dates of 2005 and 2006. The tax court adopted the market values for the mall parcel proposed by Hennepin County in its post-trial brief, which were higher than the value opinions presented by either party's appraiser at trial. On appeal, the Supreme Court concluded the tax court's value determinations were not supported by the record and remanded with instructions for the tax court to explain its reasoning and describe the factual support in the record for its determinations. On remand, the tax court adopted market values that exceeded its earlier determinations. The Supreme Court reversed, holding that the tax court failed to follow the Court's remand instructions because the tax court failed to explain its reasoning and describe the factual support in the record for its determinations. Remanded. View "Eden Prairie Mall, LLC v. County of Hennepin" on Justia Law

The subject property was located at 44 Lafayette Road in Saint Paul. Relators challenged the County's assessments for the assessment dates 2007, 2008, and 2009. After trial, the tax court adopted the market values proposed by the County in its post-trial brief, which were higher than the value opinions presented by either party's appraiser at trial. The Supreme Court reversed and remanded with instructions for the tax court to explain its reasoning for rejecting the appraisal testimony and to describe the factual support in the record for its determinations. On remand, the tax court again adopted market values that exceeded the parties' appraisal opinions. The Supreme Court reversed, holding that the tax court failed to follow the Court's remand instructions in its calculation of parking income and expenses. Remanded for a further evidentiary hearing regarding the appropriate calculation of net parking income. View "444 Lafayette, LLC v. County of Ramsey" on Justia Law

Relator was at all times relevant to this case employed by the National Basketball Association as a referee. Relator did not file Minnesota income tax returns for the 2003 and 2004 tax years but subsequently filed a 2003 state tax return as a part-year Minnesota resident. The Commissioner of Revenue determined that Relator was a full-time, legal resident of Minnesota during the relevant tax years. Relator appealed, asserting that, in 2003, he established his domicile in Florida. The Commissioner again determined that Relator was a full-time Minnesota resident during the 2003 and 2004 tax years, and the tax court affirmed. The Supreme Court affirmed, holding that sufficient evidence supported the tax court's decision, and the court correctly concluded that Relator failed to carry his burden of overcoming the legal presumption that he remained domiciled in Minnesota during the 2003 and 2004 tax years. View "Mauer v. Comm'r of Revenue" on Justia Law

On their 2007 Minnesota individual income tax return, John and Deborah Billion claimed a $55,904 deduction for carryover losses incurred in 2005 by a Minnesota subchapter S corporation in which John Billion was a shareholder. The Minnesota Commissioner of Revenue disallowed the Billions' deduction, resulting in an assessment of $3,736 in additional Minnesota income taxes for the 2007 tax year. The tax court upheld the assessment. The Supreme Court affirmed in part and reversed in part, holding (1) the Billions were entitled to a carryover net operating loss deduction of $7,834 on their 2007 individual income tax return; but (2) the tax court did not err in its judgment in all other respects. Remanded for recalculation of the Billions' Minnesota income tax liability for the 2007 tax year. View "Billion v. Comm'r of Revenue" on Justia Law