Minnesota Mining & Manufacturing Co. v. Conrad

GIERKE, Justice.

Minnesota Mining and Manufacturing Company [3M] appeals from a district court judgment upholding the State Tax Commissioner’s assessment of $27,372 in additional corporation income tax, penalty and interest against 3M for tax years 1979 through 1981, and denial of 3M’s request for a refund of $76,967 for those same years. We reverse and remand.

After an audit of 3M’s 1979, 1980, and 1981 tax returns, the Commissioner issued a Notice of Determination and Assessment of additional corporation income tax against the company. The Commissioner determined that 3M had overpaid its 1979…