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BCBSM, INC. v. COMMISSIONER OF REVENUE

No. C8-02-1647.

663 N.W.2d 531 (2003)

BCBSM, INC. (d/b/a Blue Cross-Blue Shield of Minnesota), Respondent, v. COMMISSIONER OF REVENUE, Relator.

Supreme Court of Minnesota.

June 12, 2003.

Attorney(s) appearing for the Case

Mike Hatch, Attorney General, Craig R. Anderson, Asst. Attorney General, St. Paul, MN, for Relator.

Walter A. Pickhardt, Lisa R. Pugh, Faegre & Benson LLP, Minneapolis, MN, for Respondent.

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

OPINION

MEYER, Justice.

The issue in this case is whether premiums received by an insurer on stop-loss insurance policies issued to employers who self-fund health care coverage for their employees are subject to a premium tax under Minn.Stat. § 60A.15, subd. 1(b) (1996) (current version at Minn.Stat. § 297I.05 (2002)). BCBSM, Inc. (d/b/a Blue Cross-Blue Shield of Minnesota) (hereinafter Blue Cross) appealed to the Minnesota Tax Court from an adverse...

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