Justia Tax Law Opinion Summaries

After the Commissioner denied Kimberly-Clark's corresponding refund claims that accompanied amended corporate franchise tax returns, Kimberly-Clark appealed to the tax court. Kimberly-Clark argued that its refund claims were allowable because the Legislature’s enactment of the Multistate Tax Commission’s apportionment formula was a contractual obligation that was unconstitutionally impaired when the 1987 Legislature repealed the provisions that authorized the use of that formula. The Minnesota Tax Court concluded that the Legislature’s 1987 repeal of the apportionment formula was constitutional and therefore the Commissioner properly denied Kimberly Clark’s refund claims. Kimberly-Clark petitioned for review. The court concluded that the Legislature made no unmistakable commitment in 1983 when it enacted Multistate Tax Compact, Minn. Stat. 290.171 that was impaired when the Legislature later repealed portions of that statute. Accordingly, the court affirmed the judgment. View "Kimberly-Clark Corp. Commissioner" on Justia Law

When Daniel Berglund refused to file Minnesota income tax returns for tax years 2008, 2009, and 2010, the Minnesota Department of Revenue prepared and filed returns for Berglund and mailed him Notices of Commissioner Filed Returns for the relevant tax years. In total, the Commissioner of Revenue assessed $668,840 in unpaid taxes, penalties, and interest for the three-year period. Berglund appealed, arguing that because the returns did not contain the Commissioner’s signature they were invalid and unenforceable. The tax court granted the Commissioner’s motion for judgment on the pleadings, finding that the lack of a “manual signature” was of no consequence. The Supreme Court affirmed, holding that the relevant statutes do not require that the Commissioner sign commissioner-filed returns in order for those returns to be valid. View "Berglund v. Comm’r of Revenue" on Justia Law

When Daniel Berglund refused to file Minnesota income tax returns for tax years 2008, 2009, and 2010, the Minnesota Department of Revenue prepared and filed returns for Berglund and mailed him Notices of Commissioner Filed Returns for the relevant tax years. In total, the Commissioner of Revenue assessed $668,840 in unpaid taxes, penalties, and interest for the three-year period. Berglund appealed, arguing that because the returns did not contain the Commissioner’s signature they were invalid and unenforceable. The tax court granted the Commissioner’s motion for judgment on the pleadings, finding that the lack of a “manual signature” was of no consequence. The Supreme Court affirmed, holding that the relevant statutes do not require that the Commissioner sign commissioner-filed returns in order for those returns to be valid. View "Berglund v. Comm’r of Revenue" on Justia Law

When Respondents filed their Minnesota tax return for tax year 2007, they claimed they were part-year residents of the state. After an audit, the Commissioner of Revenue determined that Respondents were full-year residents of Minnesota for that year and assessed additional income tax, penalties, and interest. On appeal, the tax court granted summary judgment in favor of Respondents, concluding that Respondents were not “residents” under Minn. Stat. 290.01. The Supreme Court reversed, holding (1) the statute is ambiguous; and (2) the tax court’s interpretation of the statute was erroneous. Remanded to the tax court for a recalculation of Respondents’ tax debt in accordance with this opinion. View "Curtis G. v. Comm’r of Revenue" on Justia Law

After completing an audit of Taxpayers' joint income tax returns, the Commissioner of Revenue issued an order assessing additional taxes. That day, a revenue tax specialist sent Taxpayers an e-mail informing them of the existence of the order. The order was attached to the e-mail. Taxpayers claimed to have been unable to open the attachment containing the letter until sixty-six days after receiving the e-mail. The specialist claimed that he also sent the order by regular mail to Taxpayers' home address, but Taxpayers contended that a mailed copy of the order never arrived. Fifty-three days after Taxpayers opened the e-mail attachment and 119 days after they received the e-mail, Taxpayers filed an appeal with the tax court. The tax court dismissed the appeal as untimely, as it was filed after the sixty-day statutory deadline. The Supreme Court affirmed, holding (1) the tax court's findings that sending the order to Taxpayers electronically and by regular mail was sufficient were not clearly erroneous; and (2) the methods by which the Commissioner sent the order did not violate Taxpayers' due process rights. View "Turner v. Comm'r of Revenue" on Justia Law

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