(dissenting).
I respectfully dissent.
At one time, I labored under the impression that I would soon be able to gracefully acquiesce to our court’s jurisprudence with respect to the interpretation of Minn.Stat. *334§ 278.05, subd. 6(a) (2006) — commonly known as the 60-day rule. Unfortunately, the case before us today does not present such an opportunity. The majority’s potentially limitless interpretation of the word including essentially turns disclosure procedures for a real property owner into a guessing game in which the end result will all too often be an “I gotcha” that ends in summary dismissal. The majority articulates a rule that is at best, too vague, and at worst, without limits. Based on today’s decision, my best advice to property owners who wish to contest their property tax assessment is to crank up the copy machine and provide absolutely everything they have within 60 days.
In the case before us, Irongate provided the county with income statements and rent records for the subject property within the 60-day time frame. Approximately six weeks later, the county asked for additional information including leases for the subject property. Irongate disputed the county’s need for this information and asserted that all of the income expense information contained in the leases, and required by the statute, was contained in the income and expense rolls already provided to the county. Irongate did, however, provide a lease abstract which it asserts contained all of the lease Information relevant to the tax proceedings. It was only after this dispute over the delivery of the leases arose, that the county, six months after the deadline expired and four months after its request for the leases, filed its motion to dismiss Irongate’s petition for failure to comply with the 60-day rule. The record does not provide us with information as to the relative equities of this discovery dispute, but in essence that is what it is — a run-of-the-mill discovery dispute.
The majority’s holding turns ordinary discovery disputes into nearly sure-fire grounds for counties to obtain summary dismissal of petitions challenging real property valuations. I do not believe that this is the intended result of the statute. I would reverse the decision of the Minnesota Tax Court and permit this case to go forward on its merits pending resolution of any further discovery disputes.
I respectfully dissent.