Northern States Power Co. v. Commissioner of Revenue

OPINION

PAGE, Justice.

Northern States Power Company (“NSP”) and United Power Association (“UPA”) sepa rately purchased step-down, load tap, and line transformers between June 1, 1990, and March 31, 1994, for use in their business operations. Each paid the Minnesota sales tax on the transformers they purchased and then each filed for refunds of those taxes, claiming that the transformers are exempt from the sales tax as capital equipment under Minn.Stat. § 297A.25, subd. 42 (1992). The Commissioner of Revenue denied their refund claims, finding that none of the transformers qualified as exempt…