Watlow Winona, Inc. v. Commissioner of Revenue

TOMLJANOVICH, Justice.

We are asked to decide whether the tax court properly concluded that Watlow Wi-nona was engaged in a unitary business with its parent company Watlow Electric and other Watlow subsidiaries, during tax years 1984 through 1987. There is substantial evidence in the record to support the tax court’s determination that the businesses were unitary during the tax years in question. Under the Minnesota Income Tax Statute and the United States Constitution, the taxpayer in this case had the burden of proving that it was not unitary with its owner and its owner’s other…