OPINION
ANDERSON, RUSSELL A., Justice.
If the taxpayer is the prevailing party in a contested tax case between the taxpayer and the Commissioner of Revenue, the taxpayer is entitled to costs and disbursements if the taxpayer shows that the position of the commissioner was not substantially justified. See Minn.Stat. § 15.472 (2004); Minn.Stat. § 271.19 (2004). This acrimonious tax case, involving issues that we have addressed in two previous...
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