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STELZNER v. COMMISSIONER OF REVENUE

No. C0-00-715.

621 N.W.2d 736 (2001)

Donald G. STELZNER, et al., Relators, v. COMMISSIONER OF REVENUE, Respondent.

Supreme Court of Minnesota.

February 8, 2001.

Attorney(s) appearing for the Case

Regan & Vincent, PLC, Thomas M. Regan, Minneapolis, for Relators.

Mike Hatch, Attorney General, Craig R. Anderson, Assistant Attorney General, Tax Litigation Division, St. Paul, for Respondent.

Considered and decided by the court en banc without oral argument.

OPINION

BLATZ, Chief Justice.

Relators Donald and Donna Stelzner appeal from the Minnesota Tax Court's decision affirming an order of the Commissioner of Revenue assessing Minnesota state income taxes, penalties, and interest for each of the taxable years from 1987 through 1993. On appeal to the tax court, the Stelzners argued that they were domiciled in Nevada, not Minnesota, and raised federal constitutional issues challenging the tax assessment. In the...

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