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U.S. BANK NATIONAL v. DEPT. OF REVENUE

#29338.

980 N.W.2d 936 (2022)

2022 S.D. 59

U.S. BANK NATIONAL ASSOCIATION, Appellant, v. SOUTH DAKOTA DEPARTMENT OF REVENUE, Appellee.

Supreme Court of South Dakota.

Opinion Filed October 5, 2022.

Attorney(s) appearing for the Case

CRAIG B. FIELDS , NICOLE L. JOHNSON of Blank Rome LLP, New York, New York, JUSTIN L. BELL of May, Adam, Gerdes & Thompson LLP, Pierre, South Dakota, Attorneys for appellant.

JOHN T. RICHTER of South Dakota Department of Revenue, Pierre, South Dakota, Attorneys for appellee.

[¶1.] The South Dakota Department of Revenue (the Department) rejected U.S. Bank's1 method of calculating its federal income tax deduction from net income subject to South Dakota's bank franchise tax for tax years 2010, 2011, and 2012. As a result, the Department denied U.S. Bank's request for a...

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