Hohmann v. Commissioner of Revenue

OPINION

ANDERSON, G. BARRY, Justice.

This case arises from the Minnesota Tax Court’s dismissal of relator Andrew Hoh-mann’s appeal for lack of subject matter jurisdiction due to late filing. The parties do not dispute the facts in this ease — i.e., that the relevant appeal documents were not received by the tax court until after the filing deadline had passed. The sole legal issue before us is whether late filing of an appeal to the tax court deprives that court of subject matter jurisdiction. We conclude that it does. We affirm.

In December 2008, the Commissioner of Revenue ordered Hohmann to…