Humana MarketPoint, Inc., Relator, vs. Commissioner of Revenue, Respondent
Supreme Court of Minnesota
1. Under Minnesota Statutes section 290.191, subdivision 5(j) (2024), which prescribes that “[r]eceipts from the performance of services must be attributed to the state where the services are received,” the term “received” is not limited to receipt by a direct customer. 2. Under the unique circumstances of this case, and because the taxpayer failed to meet its burden to prove that the Commissioner of Revenue’s tax assessment was invalid, the tax court did not err by granting…
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1. Under Minnesota Statutes section 290.191, subdivision 5(j) (2024), which prescribes that “[r]eceipts from the performance of services must be attributed to the state where the services are received,” the term “received” is not limited to receipt by a direct customer. 2. Under the unique circumstances of this case, and because the taxpayer failed to meet its burden to prove that the Commissioner of Revenue’s tax assessment was invalid, the tax court did not err by granting summary judgment to the Commissioner. Affirmed.
1Opinion of the Court
STATE OF MINNESOTA IN SUPREME COURT A25-0058 Tax Court Procaccini, J. Humana MarketPoint, Inc., Relator, vs. Filed: September 24, 2025 Office of Appellate Courts Commissioner of Revenue, Respondent. ________________________ Masha M. Yevzelman, Dylan B. Saul, Fredrikson & Byron, P.A., Minneapolis, Minnesota, for relator. Keith Ellison, Attorney General, Jennifer A. Kitchak, Assistant Attorney General, Saint Paul, Minnesota, for respondent. ________________________ SYLLABUS 1. Under Minnesota Statutes section 290.191, subdivision 5(j) (2024), which prescribes that “[r]eceipts from the…
2Cases cited18 opinions
- Wisconsin v. J. C. Penney Co.Supreme Court of the United States · 1941
- Container Corp. of America v. Franchise Tax BoardSupreme Court of the United States · 1983
- Lubbers v. AndersonSupreme Court of Minnesota · 1995
- State v. ThonesavanhSupreme Court of Minnesota · 2017
- ILHC OF EAGAN, LLC v. County of DakotaSupreme Court of Minnesota · 2005
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