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JOHN HANCOCK MUT. v. COM'R OF REVENUE

No. C2-92-975.

497 N.W.2d 250 (1993)

JOHN HANCOCK MUTUAL LIFE INSURANCE COMPANY, and Mutual Service Life Insurance Company, Respondents, v. The COMMISSIONER OF REVENUE, Relator.

Supreme Court of Minnesota.

March 19, 1993.

Attorney(s) appearing for the Case

Hubert H. Humphrey, III, Atty. Gen., Michele M. Owen, Special Asst. Atty. Gen., St. Paul, for relator.

Walter A. Pickhardt, Faegre & Benson, Minneapolis, for respondents.

Heard, considered and decided by the court en banc.

WAHL, Justice.

Relator Commissioner of Revenue (Commissioner) appeals a decision of the Tax Court holding that respondent insurance companies may claim a Minnesota Comprehensive Health Association assessment as a credit against the companies' 1986 Minnesota income taxes under Minn.Stat. § 290.06, subd. 3f(6) (1986) as well as an offset against the premium tax under Minn.Stat. § 62E.11, subd. 8 (1986). If the credit is not authorized against state income...

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