Dreyling v. Commissioner of Revenue

OPINION

ANDERSON, RUSSELL A., Chief Justice.

Relators Roger and Carol Dreyling appeal a tax court judgment affirming an order of the Commissioner of the Minnesota Department of Revenue (the commissioner) assessing additional income taxes, penalties, and interest for tax years 1998, 1999, and 2000. 1 We affirm the judgment of the tax court as to the additional income taxes, interest, and penalties assessed for substantial underpayment under Minn. Stat. § 289A.60, subd. 4 (2004), but reverse as to the assessment of penalties for fraud under Minn.Stat. § 289A.60, subd. 6 (2004).

Roger Dreyling…