Court Cases

Humana MarketPoint Inc. v. Commissioner of Revenue

On September 24, 2025, the Minnesota Supreme Court affirmed the decision of the Minnesota Tax Court that the taxpayer failed to meet its burden to prove to that the Commissioner of Revenue's tax assessment was invalid. The Court also held that the term "received" in Minnesota Statutes 2024, section 290.191, subdivision 5(j), is not limited to receipt by a direct customer. 

Revenue will follow the Minnesota Supreme Court decision.

Citation: Humana MarketPoint, Inc. v. Comm'r of Revenue, 25 N.W.3d 841 (Minn. 2025)

E. I. duPont de Nemours & Co. & Subsidiaries v. Commissioner of Revenue

On August 27, 2025, the Minnesota Supreme Court affirmed the decision of the Minnesota Tax Court that the Commissioner of Revenue satisfied his burden by demonstrating that the general apportionment method misrepresented appellant's Minnesota activities, and that an alternative formula fairly represented appellant's Minnesota activities. 

Revenue will follow the Minnesota Supreme Court decision.

Citation: E. I. duPont de Nemours & Co. & Subsidiaries v. Comm'r of Revenue, 25 N.W.3d 381 (Minn. 2025)

Uline Inc. v. Commissioner of Revenue

On August 7, 2024, the Minnesota Supreme Court affirmed the decision of the Minnesota Tax Court that the marketing research performed by Uline sales representatives is not protected from Minnesota state income or franchise taxation.

Revenue will follow the Minnesota Supreme Court decision.

Citation: Uline, Inc. v. Comm'r of Revenue, 10 N.W.3d 170 (Minn. 2024)

Wendell v. Commissioner of Revenue

On June 5, 2024, the Minnesota Supreme Court affirmed the decision of the Minnesota Tax Court that the Commissioner of Revenue has the authority to adjust a taxpayer's reported federal adjusted gross income when determining the correct amount of state income tax owed by the taxpayer, and that the penalty for filing a frivolous tax return is constitutional.

Revenue will follow the Minnesota Supreme Court decision.

Citation: Wendell v. Comm'r of Revenue, 7 N.W.3d 405 (Minn. 2024)

Dakota Drug Inc. v. Commissioner of Revenue

On November 6, 2024, the Minnesota Supreme Court affirmed the decision of the Minnesota Tax Court and held “gross revenues,” as defined in Minnesota Statutes, section 295.52, subdivision 3 (2018), does not include certain rebate payments made to a wholesale drug distributor’s customer. 

Revenue will follow the Minnesota Supreme Court decision.

For more information about this case, go to MinnesotaCare Rebates and Gross Revenues.

Citation: Dakota Drug, Inc. v. Comm'r of Revenue, 13 N.W.3d 387 (Minn. 2024)

Soo Line Railroad Co. v. Commissioner of Revenue

On February 7, 2024, the Minnesota Tax Court determined in Soo Line Railroad Co. v. Commissioner of Revenue that, beginning in tax year 2013, the Minnesota railroad track maintenance subtraction can be used for expenses that were disallowed as a deduction on your federal return due to claiming the federal railroad track maintenance credit regardless of when the asset was purchased. 

Revenue will follow the Minnesota Tax Court decision.

For more information about this case, go to Railroad Track Maintenance Subtraction.

Citation: Soo Line R.R. Co. v. Comm'r of Revenue, No. 9557-R, 2024 WL 481289 (Minn. Tax Feb. 7, 2024)

Barrett v. Commissioner of Revenue

On September 12, 2025, the Minnesota Tax Court granted the Commissioner's motion for summary judgement against Ms. Barrett for challenging an expired return, on the grounds that there are no material facts in dispute and as a matter of law the Commissioner's Order should be affirmed.

Revenue will follow the Minnesota Tax Court decision.

Citation: Barrett v. Comm'r of Revenue, No. 9628-R, 2025 WL 2639629 (Minn. Tax Sept. 12, 2025)

Wilburn v. Commissioner of Revenue 

On April 29, 2025, the Minnesota Tax Court granted the Commissioner’s motion for a default judgment against Mr. Wilburn, who did not appear for trial.

Revenue will follow the Minnesota Tax Court decision.

Citation: Wilburn v. Comm’r of Revenue, No. COR-9587, 2025 WL 1242995 (Minn. Tax Apr. 29, 2025)

Wildeman v. Commissioner of Revenue

On April 7, 2025, the Minnesota Tax Court dismissed Ms. Wildeman’s appeal for lack of subject matter jurisdiction, because the Commissioner's Demand for Payment is not an appealable order.

Revenue will follow the Minnesota Tax Court decision.

Citation: Wildeman v. Comm’r of Revenue, No. 9705-R, 2025 WL 1036958 (Minn. Tax Apr. 7, 2025)

Roxberg v. Commissioner of Revenue

On January 30, 2025, the Minnesota Tax Court dismissed Ms. Roxberg’s appeal for lack of subject matter jurisdiction for untimely filing of tax appeal and for failure to properly serve or provide proof of the service of the tax appeal on the Commissioner. 

Revenue will follow the Minnesota Tax Court decision.

Citation: Roxberg v. Comm'r of Revenue, No. COR-9687, 2025 WL 350084 (Minn. Tax Jan. 30, 2025) 

Ramos v. Commissioner of Revenue

On December 5, 2024, the Minnesota Tax Court dismissed Ms. Ramos’ appeal for lack of subject matter jurisdiction because Ms. Ramos failed to serve the Commissioner, or to file proof of service with the Tax Court. 

Revenue will follow the Minnesota Tax Court decision.

Citation: Ramos v. Comm'r of Revenue, No. 69DU-CV-24-1064, 2024 WL 4997642 (Minn. Tax Dec. 5, 2024)

Hooper v. Commissioner of Revenue

On November 8, 2024, the Minnesota Tax Court dismissed Ms. Hooper’s appeal for lack of subject matter jurisdiction because she did not submit evidence demonstrating that she timely served the Commissioner.

Revenue will follow the Minnesota Tax Court decision.

Citation: Hooper v. Comm'r of Revenue, No. 9666-R, 2024 WL 4730516 (Minn. Tax Nov. 8, 2024)

Hansen v. Commissioner of Revenue

On November 6, 2024, the Minnesota Tax Court dismissed Mr. Hansen's appeal for lack of subject matter jurisdiction because the Commissioner's bank levy notice is not an appealable order, and because Mr. Hansen's Notice of appeal is untimely as to the Commissioner filed returns underlying the Commissioner's collection efforts.

Revenue will follow the Minnesota Tax Court decision.

Citation: Hansen v. Comm'r of Revenue, No. 9646-R, 2024 WL 4702586 (Minn. Tax Nov. 6, 2024)