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LUMIDATA, INC. v. COM'R OF REVENUE

No. A14-0254.

853 N.W.2d 142 (2014)

LUMIDATA, INC., Relator, v. COMMISSIONER OF REVENUE, Respondent.

Supreme Court of Minnesota.

September 10, 2014.

Attorney(s) appearing for the Case

Mark A. Pridgeon , Edina, MN, for relator.

Lori Swanson , Attorney General, Mark B. Levinger , Assistant Attorney General, Saint Paul, MN, for respondent.

Considered and decided by the court without oral argument.

OPINION

WRIGHT, Justice.

Relator LumiData, Inc., challenges the decision of the Minnesota Tax Court upholding the Commissioner of Revenue's assessment of sales tax on LumiData's software sales. LumiData argues that its software sales are nontaxable because modifications LumiData made to its software removed it from the definition of "prewritten computer software." In the alternative, LumiData argues that it had reasonable cause to believe that its software...

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