E. F. Johnson Co. v. Commissioner of Taxation

Scott, Justice.

This is an appeal by defendant commissioner of taxation from an order of the Waseca County District Court. Plaintiff, E. F. Johnson Company, is a Minnesota corporation with its only business office and place of manufacture in Waseca, Minnesota. For the period from 1961-1963, plaintiff assigned all of its income to the state of Minnesota. In 1965, it filed claims for refunds for those years on the basis that since it had carried on its business within and without Minnesota, it was entitled to apportion its net income under Minn. St. 290.17 (4) and 290.19. The commissioner of…