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DREYLING v. COMMISSIONER OF REVENUE

No. A05-970.

711 N.W.2d 491 (2006)

Carol DREYLING, et al., Relators, v. COMMISSIONER OF REVENUE, Respondent.

Supreme Court of Minnesota.

March 30, 2006.

Attorney(s) appearing for the Case

John E. Mack, Mack & Daby, P.A., New London, MN, for Relators.

Michael Hatch, Minnesota Attorney General, Craig R. Anderson, Assistant Attorney General, Minnesota Commissioner of Revenue, Daniel A. Salmone, St. Paul, MN, for Respondent.

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

OPINION

ANDERSON, RUSSELL A., Chief Justice.

Relators Roger and Carol Dreyling appeal a tax court judgment affirming an order of the Commissioner of the Minnesota Department of Revenue (the commissioner) assessing additional income taxes, penalties, and interest for tax years 1998, 1999, and 2000.1 We affirm the judgment of the tax court as to the additional income taxes, interest, and penalties assessed for substantial underpayment...

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