Cited by

We presume that the Commissioner’s tax assessments are “valid and correctly determined.” F-D Oil Co. v. Comm’r of Revenue

Orders of the Commissioner are presumed valid and the taxpayer bears the burden to overcome that presumption, F-D Oil Co. v. Comm’r of Revenue

d 701, 706 (Minn. 1997).

of witnesses.” F-D Oil Co. v. Comm’r of Revenue, see Eden Prairie Mall, LLC, d at 21.

F-D Oil Co. v. Comm’r of Revenue

See Bums v. Comm’r of Revenue, FD Oil Co., Inc. v. Comm’r of Revenue

F-D Oil Co., Inc. v. Comm’r of Revenue

6); F-D Oil Co., Inc. v. Comm’r of Revenue, -08 (Minn.1997).

We review questions of law de novo, F-D Oil Company, Inc. v. Comm’r of Revenue, Morton Bldgs., d at 257 , but reverse factual findings only where a review of the entire record leaves us with “ ‘a firm conviction that a mistake has been made,’ ” see Krech v. Comm’r of Revenue, (quoting Montgomery Ward & Co., Inc. v. County of Hennepin

F-D Oil Co. v. Comm’r of Revenue

F-D Oil Co. v. Comm’r of Revenue

3 (1996); (stating that “the burden of demonstrating the incorrectness or invalidity of the commissioner’s assessments” is on the taxpayer).

16 (stating word “shall” is mandatory); see, (holding Chapter 289A applies to income taxes administered by commissioner and Minn. Stat. § 289A.35 (1996) makes commissioner responsible for examining returns and making investigations).

After recognizing and weighing the witnesses’ con *28 flicting interests, the court ultimately “f[ou]nd [Larson’s] arguments and testimony incredible.” When the tax court’s findings of fact are challenged on appeal, “this court reviews the record to determine whether there is sufficient evidence to support the decision.”