Soyka v. Commissioner of Revenue

OPINION

STRAS, Justice.

The question presented in this case is whether the Minnesota Tax Court has subject matter jurisdiction over an appeal when a taxpayer fails to file a notice of appeal within 60 days after notice of the making and filing of an order of the Commissioner of Revenue. The tax court dismissed Soyka’s appeal for lack of subject matter jurisdiction. We affirm.

I

On January 19, 2012, the Commissioner of Revenue (“the Commissioner”) ordered relator Sharon A. Soyka to pay $9,126.55 in income taxes, penalties, and interest for the 2007 tax year. Soyka then had 60 days — or until March…