Chapman v. Commissioner of Revenue

OPINION

ANDERSON, RUSSELL A., Justice.

Individual taxpayers subject to the Minnesota alternative minimum tax (AMT) are permitted a charitable contribution deduction if the contribution is made “to or for the use of’ a charitable organization “located in and carrying on substantially all of its activities in the [State of Minnesota].” Minn.Stat. §§ 290.091, subd. 2(f), and 290.21, subd. 3(b) (1994). In this case, we are asked to determine whether rela-tors’ contributions to a Massachusetts donor-advised charitable gift fund qualified for deduction under Minnesota’s AMT provisions and, if not,…