OPINION
MAGNUSON, Chief Justice.
Relator Stewart Title Guaranty Company ("Stewart") challenges the imposition of the Minnesota premium tax, Minn.Stat. § 60A.15 (1998) and Minn.Stat. § 297I.05 (2006), on the portion of premiums paid to its agents and never remitted to Stewart. The Minnesota Tax Court held that Stewart owed premium tax on the full premium paid by the customer, including the portion retained by agents. We affirm the decision of the...
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