Terrance W. Sargent, Relator,
Commissioner of Revenue, Respondent.
Court Office of Appellate Courts
Terrance W. Sargent, Janesville, Minnesota, pro se.
Swanson, Attorney General, Kristine K. Nogosek, Assistant
Attorney General, Saint Paul, Minnesota, for respondent.
arguments that Minnesota's income tax violates the United
States Constitution and the Minnesota Constitution are
and decided by the court without oral argument.
Minnesota Tax Court affirmed the Commissioner of
Revenue's order that assessed relator Terrance W.
Sargent's income tax liability for tax years 2010-2014.
Sargent argues that he is not subject to Minnesota's
income tax because it violates the United States Constitution
and the Minnesota Constitution. Because Sargent's
arguments are without merit, we affirm.
failed to file Minnesota income tax returns or pay income tax
for tax years 2010, 2011, 2012, 2013, and 2014. In 2016, the
Commissioner issued an order assessing Sargent's income
tax liability for those years. Sargent administratively
appealed the assessment, arguing that Minnesota's income
tax violates the United States Constitution and the Minnesota
Constitution. The Commissioner affirmed the assessment.
then appealed to the tax court, and the parties filed cross
motions for summary judgment. The tax court granted the
Commissioner's motion and denied Sargent's motion.
Sargent v. Comm'r of Revenue, No. 9019-R, 2017
WL 6813394, at *1 (Minn. T.C. Dec. 15, 2017). This case is
now before us on certiorari. See Minn. Stat. §
271.10, subd. 1 (2016) (providing for "review of any
final order of the Tax Court . . . upon certiorari by the
review the tax court's legal conclusions de novo."
Gonzales v. Comm'r of Revenue, 706 N.W.2d 909,