Soyka v. Comm’r of Revenue
Annotate this CaseThe Commissioner of Revenue informed Sharon Soyka by a notice that it would file a tax return on her behalf for the 2008 tax year and asserting that Soyka owed $2,201 in income taxes, interest, and penalties. Exactly sixty-one days after the Commissioner mailed the notice, Soyka mailed her notice of appeal to the Minnesota Tax Court. The tax court dismissed Soyka’s appeal, concluding that it was untimely under Minn. Stat. 271.06(2), which generally requires a notice of appeal to be filed within sixty days after notice of an order by the Commissioner. At issue before the Supreme Court was whether, when the Commissioner serves notice of an order by United States mail, Minn. R. Civ. P. 6.05 extends the sixty-day statutory deadline for filing an appeal with the tax court. The Supreme Court reversed and directed the tax court to reinstate Soyka’s appeal, holding that Rule 6.05 applies and extends the statutory filing deadline by three days when the Commissioner serves the notice by United States mail.
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