Ralston Purina Co. v. Commissioner of Revenue

Peterson, Justice.

The issue in this case involves the application of the three-factor formula for allocation of net income of a business carried on partly within and partly without this state. Minn. St. 290.19.

Ralston Purina Company, the taxpayer, is based in St. Louis, Missouri, and is authorized to do business in Minnesota. It manufactures and sells food products both within and without Minnesota. Its sales in Minnesota are generated through independent broker representatives which have their offices in Minnesota and solicit orders for Ralston from Minnesota customers, principally from…