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NORTHERN STATES POWER v. COM'R OF REV.

No. C9-97-698.

571 N.W.2d 573 (1997)

NORTHERN STATES POWER COMPANY, et al., Relators, v. COMMISSIONER OF REVENUE, Respondent.

Supreme Court of Minnesota.

November 20, 1997.

Attorney(s) appearing for the Case

Sue Ann Nelson, Steven G. Mahon, Tracy N. Smith, Doherty, Rumble & Butler, P.A., Minneapolis, for relators.

Hubert H. Humphrey III, Atty. Gen., Barry R. Greller, Asst. Atty. Gen., Tax Litigation Division, St. Paul, for respondent.

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

OPINION

PAGE, Justice.

Northern States Power Company ("NSP") and United Power Association ("UPA") separately purchased step-down, load tap, and line transformers between June 1, 1990, and March 31, 1994, for use in their business operations. Each paid the Minnesota sales tax on the transformers they purchased and then each filed for refunds of those taxes, claiming that the transformers are exempt from the sales...

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