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  5. 997 N.W.2d 348 (2023)
 

CITIES MANAGEMENT v. COM'R OF REVENUE

A23-0222.

997 N.W.2d 348 (2023)

CITIES MANAGEMENT, INC., Relator, v. COMMISSIONER OF REVENUE, Respondent.

Supreme Court of Minnesota.

Filed: November 22, 2023.

Attorney(s) appearing for the Case

Masha M. Yevzelman , Jennifer R. Pusch , Fredrikson & Byron, P.A., Minneapolis, Minnesota, for relator.

Keith Ellison , Attorney General, Jennifer A. Kitchak , Assistant Attorney General, Saint Paul, Minnesota, for respondent.

Benjamin A. Wagner , Kathleen E. Pfutzenreuter , Wagner Tax Law, Minneapolis, Minnesota, for amici curiae Minnesota Society of Certified Public Accountants and Minnesota Chamber of Commerce.

OPINION

This case concerns the authority of the Commissioner of Revenue to apportion the income of a nonresident under Minn. Stat. § 290.17 (2014).1 Relator Cities Management, Inc. (CMI) is an S corporation that did business in Minnesota...

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