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SHARE v. COMMISSIONER OF REVENUE

No. C1-84-1277.

363 N.W.2d 47 (1985)

SHARE, Relator, v. The COMMISSIONER OF REVENUE, Respondent.

Supreme Court of Minnesota.

February 22, 1985.

Attorney(s) appearing for the Case

Bruce E. Hanson, Doherty, Rumble & Butler, P.A., St. Paul, for relator.

Hubert H. Humphrey III, Atty. Gen., James W. Neher, Sp. Asst. Atty. Gen., St. Paul, for respondent.

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

PETERSON, Justice.

SHARE, a health maintenance organization, filed for a certificate of exempt status from sales and use tax as a purely public charity under Minn.Stat. § 297A.25, subd. 1(p) (1984). SHARE claimed entitlement to the exemption because it provides non-profit health care to a cross section of the community. The Commissioner of Revenue denied the exemption, asserting that SHARE is not an institution of purely public charity, and the tax court upheld...

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