State v. Northwestern States Portland Cement Co.

*34Matson, Justice.

Defendant taxpayer, a foreign corporation engaged exclusively in interstate commerce, appeals from a judgment in a proceeding by the State of Minnesota to collect income taxes — together with penalties and interest — upon that portion of the taxpayer’s total net income which is allocable to Minnesota. The allocated tax relates to income derived solely from interstate commerce business conducted in this state.1

Three questions are presented on appeal:(1) Does the taxpayer have sufficient contact with the State of Minnesota to make it amenable to service of process and subject to…