E. I. duPont de Nemours and Company & Subsidiaries, Relator v. Commissioner of Revenue

Syllabus

The tax court correctly found that the Commissioner of Revenue satisfied his burden under Minnesota Statutes section 290.20 (2024) by demonstrating that the general apportionment method in section 290.191 (2024) misrepresented appellant's Minnesota activities, and that an alternative formula—excluding gross receipts but including net income from forward exchange contracts—fairly represented appellant's Minnesota activities. Affirmed.