Commissioner of Revenue v. Enbridge Energy, Lp

Summary

The court held that Minnesota Rule 8100, including its valuation and allocation formulas, binds the tax court when determining the taxable value of a pipeline system. The tax court therefore erred by concluding that it could disregard the rule because its formula might produce an inaccurate valuation or because the rule addresses the Commissioner rather than the tax court. The court reversed and remanded for proceedings consistent with that holding.