Kmart Corporation v. County of Stearns

Summary

The Minnesota Supreme Court held that Minn. Stat. § 278.05, subd. 6(a), requires taxpayers challenging property tax assessments to provide information about tenant-paid real estate expenses within 60 days of filing a chapter 278 petition. The court affirmed dismissal of Kmart's petitions for failure to comply with that requirement and declined to apply its holding only prospectively or to grant relief under equitable estoppel.

Holdings

1. Minn. Stat. § 278.05, subd. 6(a), requires a taxpayer to provide within 60 days all useful and relevant expense information concerning income-producing property, including real-estate expenses paid by a tenant rather than the owner.
2. The purely prospective ruling doctrine does not apply to the Minnesota Tax Court's interpretation of the plain language of the 60-day rule, and Kmart was not entitled to prospective-only application of the holding.
3. Equitable estoppel did not prevent Stearns County from enforcing the 60-day rule because Kmart failed to show the required wrongful governmental conduct and did not rely on conduct by the taxing authority, Stearns County.

Questions Presented

1. Whether Minn. Stat. § 278.05, subd. 6(a), requires a taxpayer to provide information about tenant-paid real-estate expenses within 60 days after filing a chapter 278 property-tax petition.
2. Whether dismissal of Kmart's chapter 278 petitions should be relieved or the Supreme Court's interpretation applied only prospectively because Kmart relied on prior Tax Court decisions.
3. Whether equitable estoppel prevents Stearns County from obtaining dismissal based on Kmart's reliance on prior Tax Court interpretations.

Disposition

affirmed