Stewart Title Guaranty Co. v. Commissioner of Revenue

OPINION

MAGNUSON, Chief Justice.

Relator Stewart Title Guaranty Company (“Stewart”) challenges the imposition of the Minnesota premium tax, MinmStat. § 60A.15 (1998) and MinmStat. § 2971.05 (2006), on the portion of premiums paid to its agents and never remitted to Stewart. The Minnesota Tax Court held that Stewart owed premium tax on the full premium paid by the customer, including the portion retained by agents. We affirm the decision of the tax court.

Stewart is a Texas-based title insurance company licensed in Minnesota. Stewart sells title insurance policies through a network of agents…