Harbaugh v. Comm'r of Revenue
Annotate this CasePlaintiff and his ex-wife both claimed their two children as dependents on their state individual income tax returns. The Minnesota Department of Revenue determined that only Plaintiff's ex-wife was entitled to claim the children as dependents and that Plaintiff had underpaid his state taxes. Plaintiff appealed. The extended deadline for filing Plaintiff's notice of appeal was December 27. On December 22, Plaintiff mailed his notice of appeal to the tax court and the Department of Revenue. The Department received the notice on December 27, but the notice sent to the court was marked by the court as filed on December 28. The The tax court dismissed Plaintiff's appeal for lack of subject matter jurisdiction on the ground that Plaintiff had not timely filed his notice of appeal. The Supreme Court affirmed, holding (1) the mailbox rule does not extend to statutorily created rights of appeal; and (2) Plaintiff failed to present direct evidence in support of his assertion that his notice of appeal arrived on December 27.
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