SF4191 (Legislative Session 94 (2025-2026))
Evidentiary standards applying to Tax Court proceedings regarding property valuations modification
Related bill: HF3971
AI Generated Summary
Purpose
This bill changes how appeals involving property valuations for property taxes are handled in Minnesota. It alters the evidentiary rules and the review process in Tax Court to require de novo consideration, public hearings, and explicit burdens of proof, while also clarifying how certain evidence (like a sales ratio study) can be used.
Main provisions
- De novo review in Tax Court
- The Tax Court must hear, consider, and determine every appeal de novo (a fresh review) without a jury.
- Advisory jury option
- A Tax Court judge may empanel an advisory jury on the judge’s motion.
- Public hearings
- The Tax Court must hold a public hearing in every case.
- Burden of proof for property valuations
- In all cases, the order of the commissioner or the appropriate unit of government is prima facie valid.
- For property valuation cases, the appropriate unit of government has the burden of establishing the validity of the valuation.
- Original proceeding to challenge orders
- An appeal from an order or determination becomes an original proceeding in the nature of a suit to set aside or modify that order or determination.
- Absence of an appellant
- If no appellant appears, the Tax Court must affirm the order of the commissioner of revenue or the applicable unit of government.
- Evidence from the Department of Revenue’s sales ratio study
- If the Department’s sales ratio study is introduced as evidence, the sales ratio data from the study is admissible only as provided in section 278.05 subdivision 1.4.
- Filing and information-sharing
- The commissioner, the taxpayer, and any other party to an appeal may file all necessary notices, documents, and other information with the Tax Court in a manner approved by the Tax Court.
What changes in practice or law
- Shifts in review standard: Appeals are explicitly de novo, meaning the court re-examines the facts and issues rather than reviewing for simple errors.
- Burden shift for valuations: In property tax valuation cases, the government must prove the valuation’s validity, not just show that the valuation was reasonable.
- Participation and transparency: The rule requiring public hearings and the potential use of an advisory jury increases transparency and may affect how evidence is presented and contested.
- Evidence rules: The use of the Department of Revenue’s sales ratio study is tightly conditioned by the referenced statutory provision for admissibility.
Key terms to watch
- Tax Court
- de novo
- advisory jury
- public hearing
- prima facie valid
- burden of establishing the validity of the valuation
- property valuation
- commissioner of revenue
- unit of government
- original proceeding
- suit to set aside or modify
- Department of Revenue
- sales ratio study
- 278.05 subdivision 1.4
- notices and filings
Relevant Terms - Tax Court - de novo - advisory jury - public hearing - prima facie valid - burden of establishing the validity of the valuation - property valuation - commissioner of revenue - unit of government - original proceeding - suit to set aside or modify - Department of Revenue - sales ratio study - 278.05 subdivision 1.4 - notices - filings
Bill text versions
- Introduction PDF PDF file
Actions
| Date | Chamber | Where | Type | Name | Committee Name |
|---|---|---|---|---|---|
| March 09, 2026 | Senate | Action | Introduction and first reading | ||
| March 09, 2026 | Senate | Action | Referred to | Taxes |
Citations
[
{
"analysis": {
"added": [
"De novo hearing for Tax Court property valuation appeals.",
"Allowance for an advisory jury at the judge's motion.",
"Public hearing requirement in Tax Court proceedings.",
"Burden shifting to the unit of government to prove valuation validity."
],
"removed": [],
"summary": "This bill amends Minnesota Statutes 2024 section 271.06, subdivision 6 to change Tax Court proceedings for property valuation appeals, authorizing de novo hearings, allowing an advisory jury on motion, and requiring a public hearing; it also clarifies that in property valuation cases the unit of government bears the burden of establishing the valuation's validity and ties admissibility of the Department of Revenue's sales ratio study to section 278.05, subdivision 1.",
"modified": [
"Reframes and clarifies Tax Court procedural and evidentiary standards for property valuation appeals; interplays with admissibility under 278.05, subdivision 1."
]
},
"citation": "271.06",
"subdivision": "subdivision 6"
},
{
"analysis": {
"added": [],
"removed": [],
"summary": "Cites Minnesota Statutes 2024 section 278.05, subdivision 1 for the admissibility of the Department of Revenue's sales ratio study as evidence in Tax Court proceedings.",
"modified": []
},
"citation": "278.05",
"subdivision": "subdivision 1"
}
]Progress through the legislative process
In Committee