Associated Bank, N.A. v. Comm'r of Revenue

CHUTICH, Justice.

In this appeal, we consider whether the Commissioner of Revenue ("the Commissioner") properly invoked her alternative-apportionment authority under Minnesota Statutes section 290.20, subdivision 1 (2016), and if so, what burden the Commissioner bears when using that authority. Respondents Associated Bank, N.A., and its affiliates ("the Bank"), which include the members of two Wisconsin limited liability companies (LLCs), objected to the Commissioner's assessment of additional state corporate franchise tax liability for tax years 2007 and 2008. Although the Bank correctly…