Hercules Inc. v. Commissioner of Revenue

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• noting that Minnesota tax court had previously found the gain generated by plaintiffs sale of its interest in Himont could be apportioned in Minnesota
• holding the corporation’s ownership and sale of a company’s stock was not sufficiently linked to the corporation’s day-to-day operations to make gain from sale business income to apportion and corporation carried stock on its books for more than four years as investment, not assets
• “The arm’s length nature of [services Hercules provided to a corporation it created] indicates that they did not embody the requisite flow of value to create a unitary business relationship”

Source: CourtListener parenthetical corpus (CC0).