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ZIMPRO, INC. v. COMMISSIONER OF REVENUE

No. 51743.

308 N.W.2d 809 (1981)

ZIMPRO, INC., Respondent, v. COMMISSIONER OF REVENUE, State of Minnesota, Appellant.

Supreme Court of Minnesota.

August 7, 1981.

Attorney(s) appearing for the Case

Warren Spannaus, Atty. Gen., Paul Kempainen, Sp. Asst. Atty. Gen., Dept. of Revenue, St. Paul, for appellant.

Briggs & Morgan, James Littlefield and Martin Fisk, St. Paul, for respondent.

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

OTIS, Justice.

This case arises from an action for declaratory judgment in which respondent Zimpro, Inc. asks that its purchase of more than $13 million worth of sewage treatment equipment, pursuant to its performance of a contract with the Metropolitan Waste Control Commission, be declared tax exempt under Minn.Stat. § 297A.25(1)(j) (1980). That provision exempts "[t]he gross receipts from all sales of tangible personal property to * * * a state and its agencies...

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