Certain terms are frequently used in Minnesota Tax Court proceedings. The following definitions are intended as general guidance to assist in understanding, and do not constitute legal advice.
Affidavit: A written statement of facts made voluntarily and confirmed by the oath or affirmation of the party making it. Sometimes the term “declaration” is used.
Appellant : The party bringing the case, the taxpayer.
Appellee: The party against whom a claim is brought. In tax disputes, this is the commissioner of the Minnesota Department of Revenue.
Appraiser: A person with some qualified professional training and experience, engaged by a party to make a value estimate.
Assessment date: The assessment for each year is set on January 2 of the preceding year. For example, the assessment date for taxes payable in 2021 is January 2, 2020.
Assessor: The county officer charged with determining the market value and classification of property for tax purposes.
Burden of proof: The greater responsibility to prove a claim correct.
In property tax disputes, the burden of proof rests with the petitioner. In appeals from orders of the commissioner of revenue (including but not limited to income, employment, and sales tax disputes), the burden of proof rests with the Appellant.
Classification: How a property is best used as defined in Minnesota law. Classification determines the rate at which a property is taxed.
County attorney: The county’s legal representative. The county attorney defends the county’s interest in property tax cases.
Court reporter: The independent person who records all testimony presented at a trial or hearing.
Estimated market value: The assessor’s estimate of the price at which a property might sell on the open market.
Notice of Appeal: The document you signed and filed to object to the commissioner’s assessment of tax, penalty, and/or interest or the commissioner’s denial of a refund and that asks the tax court to hear your case.
Petition: The document you signed and filed contesting the value or classification of the property you own or in which you have an interest or asserting that such property was unequally assessed.
Petitioner: The person who files a petition against the county in property tax matters.
Presumption: The assessor’s estimated market value and classification are presumed valid in property tax petitions. The burden is on the petitioner to prove that the value differs or that the classification is incorrect.
The commissioner’s order is presumed valid in appeals from orders of the commissioner of revenue. The burden is on the Appellant to prove that the commissioner is wrong.
Respondent: The party against whom a claim is brought. In property tax disputes, this is the county that assessed or classified the property.
Sales Ratio Study: A comparison made by the Minnesota Department of Revenue of all sales between disinterested parties and the estimated market value of properties in a taxing district. The sales ratio is indicated as a percentage.
Settlement: An agreement reached through negotiation by parties involved in a legal dispute.
Testimony: Information supplied by people involved in a dispute. Testimony is given under oath—a legally binding promise to tell the truth.
Transcript: A written record of the testimony at trial prepared by the court reporter.
Under advisement: Under consideration by the judge.
Unequal assessment: A claim that a property was assessed at a rate higher than comparable properties in a taxing district.
Witness: An individual with information about a legal dispute who is called to provide that information to a court.
Online Resources
The Minnesota Tax Court website includes links to other websites. These linked sites are not under the control of the Minnesota Tax Court, and the court neither specifically endorses these sites nor is responsible for their content.
