Amoco Corp. v. Commissioner of Revenue

OPINION

ANDERSON, Paul H., Justice.

Relators, Amoco Corporation and eight of its fully owned subsidiaries, challenge the Commissioner of Revenue’s computation of their corporate franchise taxes for the audit period from 1986 through 1990. During the audit period, relators filed Minnesota corporate franchise tax returns on a separate entity basis and paid aggregate corporate franchise taxes in the amount of $5,132,340. After conducting an audit of relators’ returns, the Commissioner concluded that Amoco Corporation was a unitary business engaged in exploration, production, refining, and…