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INTERN. BUSINESS MACHINES v. COM'R OF REV.

A18-1740.

931 N.W.2d 814 (2019)

INTERNATIONAL BUSINESS MACHINES CORPORATION and Subsidiaries, Respondents, v. COMMISSIONER OF REVENUE, Relator.

Supreme Court of Minnesota.

Filed: July 31, 2019.

Attorney(s) appearing for the Case

Walter A. Pickhardt , Michael J. Kaupa , Faegre Baker Daniels LLP, Minneapolis, Minnesota, for respondents.

Keith M. Ellison , Attorney General, Wendy Tien , Assistant Attorney General, Saint Paul, Minnesota, for relator.

OPINION

This case requires us to interpret Minnesota's research and development (R&D) tax credit statute. Minn. Stat. § 290.068 (2010).1 Specifically, we must answer two questions. First, does the Minnesota Legislature's incorporation of the federal tax code's definition of the term...

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