Custom Ag Service of Montevideo, Inc. v. Commissioner of Revenue

OPINION

PAUL H. ANDERSON, Justice.

In 2003, the Minnesota Department of Revenue assessed Custom Ag Service of Montevideo, Inc. (Custom Ag), a Minnesota corporation, with approximately $94,200 in unpaid sales and use taxes for tax years 2000, 2001, and 2002. The use taxes were assessed on grain bins and other items that Custom Ag purchased from an Indiana vendor to serve as components in grain drying systems that Custom Ag installed on Minnesota farms. Custom Ag appealed the use tax assessment to the Commissioner of Revenue on the ground that the grain bins qualified as tax-exempt grain dryers…