Christopher J. Wendell and Nancy A. Wendell, Relators v. Commissioner of Revenue

Citations

• 7 N.W.3d 405

Syllabus

1. The Commissioner of Revenue has the authority to adjust a taxpayer's reported federal adjusted gross income when determining the correct amount of state income tax owed by the taxpayer under our decision in Specktor v. Commissioner of Revenue, 308 N.W.2d 806 (Minn. 1981) and Minn. Stat. § 270C.33, subdivision 4 (2022). 2. The tax court did not err in granting summary judgment in favor of the Commissioner of Revenue. 2 3. The statutory penalty imposed for filing a frivolous tax return under Minn. Stat. § 289A.60, subd. 7 (2022), is not unconstitutional under the Due Process Clauses and Excessive Fines Clauses of the United States Constitution and Minnesota Constitution or the Equal Protection Clause of the United States Constitution. Affirmed. Considered and decided by the court without oral argument.