DREYLING v. Commissioner of Revenue

OPINION

DIETZEN, Justice.

Relators Carol and Roger Dreyling challenge the decision of the Minnesota Tax Court affirming an order of the Minnesota Commissioner of Revenue (Commissioner) assessing additional income tax and interest arising out of joint income tax returns filed by the Dreylings for taxable years 2001 and 2002. The Dreylings argue that the tax court erred in concluding that Roger Dreyling was a Minnesota resident for income tax purposes. We affirm.

Roger was born and raised in Minnesota, and married Carol in 1958. In 1966 he graduated from medical school, and later he established a…