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RALSTON PURINA CO. v. COMMISSIONER OF REVENUE

No. 45435.

236 N.W.2d 779 (1975)

RALSTON PURINA COMPANY, Respondent, v. COMMISSIONER OF REVENUE, Relator.

Supreme Court of Minnesota.

December 12, 1975.

Attorney(s) appearing for the Case

Warren Spannaus, Atty. Gen., Kenneth E. Raschke, Jr., Sp. Asst. Atty. Gen., Dept. of Revenue, St. Paul, for relator.

John S. Morrison, St. Louis, Mo., for respondent.

Heard before PETERSON, KELLY and MacLAUGHLIN, JJ., and considered and decided by the court en banc.

PETERSON, Justice.

The issue in this case involves the application of the three-factor formula for allocation of net income of a business carried on partly within and partly without this state. Minn.St. 290.19.

Ralston Purina Company, the taxpayer, is based in St. Louis, Missouri, and is authorized to do business in Minnesota. It manufactures and sells food products both within and without Minnesota. Its sales in Minnesota are generated through independent...

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