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ASSOCIATED BANK v. COMMISSIONER OF REVENUE

A17-0923.

914 N.W.2d 394 (2018)

ASSOCIATED BANK, N.A. and Affiliates, Respondents, v. COMMISSIONER OF REVENUE, Relator.

Supreme Court of Minnesota.

Filed: July 5, 2018.

Attorney(s) appearing for the Case

Walter A. Pickhardt , Faegre Baker Daniels LLP, Minneapolis, Minnesota, for respondents.

Lori Swanson , Attorney General, Jennifer A. Kitchak , Assistant Attorney General, Saint Paul, Minnesota, for relator.

Mary L. Knoblauch , Anthony Ostlund Baer & Louwagie P.A., Minneapolis, Minnesota; and Helen Hecht , Bruce J. Fort , Washington, D.C., for amicus curiae Multistate Tax Commission.

OPINION

In this appeal, we consider whether the Commissioner of Revenue ("the Commissioner") properly invoked her alternative-apportionment authority under Minnesota Statutes section 290.20, subdivision 1 (2016), and if so, what burden the Commissioner bears when using that authority. Respondents Associated Bank, N.A...

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