BCBSM, INC. v. Commissioner of Revenue

OPINION

MEYER, Justice.

The issue in this case is whether premiums received by an insurer on stop-loss insurance policies issued to employers who self-fund health care coverage for their employees are subject to a premium tax under Minn.Stat. § 60A.15, subd. 1(b) (1996) (current version at Minn.Stat. § 2971.05 (2002)). BCBSM, Inc. (d/b/a Blue Cross-Blue Shield of Minnesota) (hereinafter Blue Cross) appealed to the Minnesota Tax Court from an adverse ruling by the Commissioner of Revenue (hereinafter commissioner). The tax court reversed the commissioner’s order, finding that Blue Cross’s…