Green Giant Co. v. Commissioner of Revenue

OPINION

GARDEBRING, Justice.

This is a tax assessment case involving the issue of whether a corporation’s assignment of income made pursuant to Minn.Stat. § 290.01, subd. 20 (1987) is taxable income. 1 This section, which incorporates § 1804(e)(4) of the federal Tax Reform Act of 1986, Pub.L. No. 99-514, 100 Stat. 2800 (1986), 2 was adopted by the Minnesota Legislature as part of a 1987 bill intended to simplify the state’s income tax and bring Minnesota tax law into conformity with the federal changes. Minn.Laws.1987, ch. 268, art. 1, §§ 18, 125. The federal provision allowed profitable…