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· 8/7/2024

Uline, Inc., Relator v. Commissioner of Revenue

Syllabus

1. The mandatory practice of what amounts to market research performed by an out-of-state company's sales team in Minnesota is not considered \solicitation of orders\ under Title 15, United States Code section 381, and is therefore not protected from Minnesota state income or franchise taxation. 2. The market research performed by the company's sales team in Minnesota was not merely de minimis and therefore is not immune from Minnesota state income or franchise taxation. Affirmed.

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