Tax Court Digest: July 19, 2023

Income Tax

Brokerage Income

Appellants challenged the Commissioner of Revenue’s authority to assess individual income tax on payments they received during tax years 2019 and 2020. The Commissioner initially asked the court to affirm his 2019 tax order and his 2020 order as corrected. The court previously affirmed the 2019 order as issued, and affirmed—in part—the 2020 order, declining to grant the Commissioner’s motion concerning 2020 brokerage and interest income. By way of a second motion for summary judgment, the Commissioner now asked the court to affirm his 2020 order as corrected, based on additional information concerning the brokerage and interest income. Noting that appellants’ conclusory allegations of harm from insufficient notice or inconsistent treatment were unsupported by any factual evidence and offered without legal analysis, the Tax Court granted the motion.

9488-R, 9515-R Wendell v. Comm’r of Revenue

Property Tax

Timeliness

The county moved to dismiss this pro se property tax challenge for taxes payable in 2022 that was filed a day after the filing deadline. The Tax Court agreed that it lacked subject matter jurisdiction. Motion granted.

27-CV-22-6983 Hicks v. Hennepin County

Property Tax

Valuation

Petitioner filed a petition challenging the estimated market value of residential property in Skandia Township, alleging that it exceeded the property’s actual market value. The Tax Court concluded that the evidence petitioner presented at trial concerning the change in assessed values from years prior to the year at issue and omission from assessment of certain characteristics of the subject property did not constitute credible evidence that the assessor’s estimated market value was incorrect.

51-CV-20-129 Larson v. County of Murray