OPINION
ANDERSON, PAUL H., Justice.
Kevin Harbaugh and his ex-wife both claimed their two children as dependents on their Minnesota individual income tax returns for the 2007, 2008, and 2009 tax years. The Minnesota Department of Revenue determined that only Harbaugh's ex-wife was entitled to claim the children as dependents and that Harbaugh had underpaid his Minnesota taxes when he improperly claimed the children as dependents. Harbaugh appealed the Department...
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