Justia Tax Law Opinion Summaries

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

In 1995, Katelyn Janson was severely injured in an automobile accident. A lawsuit ended with a settlement in which two annuities were established, both of which guaranteed payments to Katelyn starting in 2001 and established that, if Katelyn died before fifteen years expired, annuity payments would be made to her estate. Katelyn's mother and conservator, Candy Bradison, moved Katelyn to Wyoming in 2001 and to Minnesota in 2003. In 2006, Katelyn died. In 2010, Bradison sought, on behalf of Katelyn's estate, a refund of the amount the estate previously paid to the Minnesota Department of Revenue, arguing (1) the annuity payments were not includable in Katelyn's estate because Katelyn did not own the annuities; and (2) Katelyn was a Wyoming domiciliary at the time of her death. The tax court concluded (1) Katelyn was a Minnesota domiciliary at the time of her death; and (2) the annuity payments were includable in Katelyn's estate. The Supreme Court affirmed, holding (1) Katelyn's intangible property had a situs in Minnesota at the time of her death and could be taxed in accordance with Minnesota's estate tax provisions; and (2) Katelyn was the beneficial owner of the annuity payments, and the value of the payments was properly included in her estate. View "Bradison vs. Comm'r of Revenue" on Justia Law

Todd County assessed taxes on property owned by John and Carrie Beck based on its conclusion that the property had an estimated market value of $397,400 as of January 2, 2009. John petitioned the tax court for relief. After a trial, the tax court found the fair market value of the property on that date was $395,000. John appealed, arguing that the tax court erred by (1) adopting the appraisal of Todd County's expert despite several challenges John raised to the assumptions and values underlying the appraisal, (2) rejecting the testimonies of John and Carrie challenging the County's assessment of the property, and (3) not determining separate land and improvement values for the property. The Supreme Court reversed because the tax court completely failed to address why it rejected the extensive evidence offered by John in support of his petition for tax relief. Remanded for the tax court to explain adequately the reasoning underlying its valuation determination. View "Beck v. County of Todd" on Justia Law

From 1999-2006, Relator filed his Minnesota individual income tax return as a nonresident. After the Commissioner of Revenue conducted two audits of Relator's individual income tax returns spanning the 2002-2006 tax years, the Commissioner determined that Relator was a resident of Minnesota during the tax years. Relator appealed, arguing that he became a resident of Nevada in 1998, and therefore, the Commissioner erred in requiring him to pay taxes as a Minnesota resident during the relevant tax years. The tax court affirmed, concluding that Relator was a Minnesota domiciliary during the tax years and, therefore, was a resident of Minnesota for income tax purposes. The Supreme Court affirmed, holding that the tax court did not err in its application of the law, and the record supported the tax court's determination. View "Larson v. Comm'r of Revenue" on Justia Law

Relators represented a putative class including all residential property owners in three Minneapolis neighborhoods. Relators challenged the assessed values that the City placed on Relators' properties and alleged that because their properties were overvalued, Relators were required to overpay property taxes in 2009 through 2011. The tax court dismissed Relators' complaint, holding (1) because Relators alleged that the City's assessment practices were illegal, Minn. Stat. 278 provided the Realtors' exclusive remedy, (2) Relators' 2008 and 2009 claims were untimely under chapter 278, and (3) Relators' 2010 claims failed because chapter 278 did not allow multiple taxpayers to file a single action concerning multiple properties. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) Relators' claims based on the 2008 and 2009 tax years were untimely pursuant to chapter 278; but (2) because the plain language of chapter 278 allows multiple taxpayers to file one tax action concerning multiple properties, the tax court erred in dismissing Relators' claims based on the 2010 tax year to the extent those claims alleged a violation of Minn. Stat. 273.11. View "Odunlade v. City of Minneapolis" on Justia Law

Relator challenged several personal liability assessments that the Commissioner of Revenue made against him based on unpaid petroleum and sales taxes owed by Twin Cities Avanti Stores, LLC (Avanti). On appeal, Relator asserted that the tax court erred by granting summary judgment to the Commissioner because (1) there were disputed, material questions of fact regarding his personal liability for the unpaid petroleum and sales taxes, and (2) the court abused its discretion in not allowing additional discovery to explore an estoppel defense. The Supreme Court reversed the tax court's grant of summary judgment in favor of the Commissioner and remanded for a trial, holding that there was a material dispute of fact whether Relator had the requisite control over the company's finances to be held personally liable for Avanti's tax liability. View "Stevens v. Comm'r of Revenue" on Justia Law