Soyka v. Commissioner of Revenue

I disagree with the majority’s conclusion that the judicial branch has the authority to extend the subject matter jurisdiction of an executive branch court. I therefore respectfully dissent. I would affirm the tax court and hold that Soyka’s appeal was untimely.

The Minnesota Legislature created the Minnesota Tax Court as part of the income tax system. See Langer v. Comm’r of Revenue, 773 N.W.2d 77, 80 (Minn.2009). We have recognized that the Legislature has “the power to fix the conditions under which [a] tax should be assessed and enforced, and therefore compliance with those conditions is…