Luther v. Commissioner of Revenue

OPINION

PAUL H. ANDERSON, J.

Relator Adelyn L. Luther appeals, by writ of certiorari, from the Minnesota Tax Court’s decision affirming the Commissioner of Revenue’s determination that Luther was a non-domiciliary resident for Minnesota income tax purposes and that, therefore, Minnesota could properly tax her worldwide income. The commissioner determined that, in 1990, Luther fit within Minnesota’s definition of a nondomiciliary resident because she (1) maintained an abode in Minnesota and (2) spent more than one-half of 1990 here. Based on this determination, the commissioner adjusted Luther’s…