Byers v. Commissioner of Revenue

OPINION

ANDERSON, Russell A., Chief Justice.

Relator Deanna L. Byers (“Byers”) appeals a Minnesota Tax Court order requiring her to pay state income tax for the tax years 1996, 1997, and 1998. She argues that (1) the tax court lacked jurisdiction; (2) it is unconstitutional to place the burden of proof on the taxpayer to show the incorrectness or invalidity of the Commissioner of Revenue’s assessment; (3) her failure to receive notice of the procedures for filing refund claims or taxpayer complaints renders the assessment invalid; and (4) there is insufficient evidence to support the tax…