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BUNGE CORP. v. COMMISSIONER OF REVENUE

No. 51202.

305 N.W.2d 779 (1981)

BUNGE CORPORATION and Bunge Export Corporation, Relators, v. The COMMISSIONER OF REVENUE, Respondent.

Supreme Court of Minnesota.

May 15, 1981.

Attorney(s) appearing for the Case

Gray, Plant, Mooty, Mooty & Bennett, Clinton A. Schroeder, John P. James and Elizabeth M. Schmidt, Minneapolis, for relators.

Warren Spannaus, Atty. Gen., and C. H. Luther, Deputy Atty. Gen., Department of Revenue, St. Paul, for respondent.

Heard, considered, and decided by the court en banc.

PETERSON, Justice.

This appeal concerns the effect, under Minnesota income tax law, of transactions between relator Bunge Corporation (hereafter Bunge) and its subsidiary, relator Bunge Export Corporation (hereafter Bunge Export), a corporation qualified as a Domestic International Sales Corporation (DISC) under federal law. Respondent Commissioner of Revenue issued an order disallowing deductions for commissions and interest paid by Bunge to Bunge Export for the...

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