Uline, Inc., Relator v. Commissioner of Revenue

Summary

The Minnesota Supreme Court affirmed the tax court’s decision that Uline’s market‑research activities performed by its Minnesota sales team are not protected as “solicitation of orders” under 15 U.S.C. §381 and that those activities are not de minimis. The Court held that the preparation of Market News Notes falls outside the statutory exemption and creates a sufficient nexus for state income and franchise taxation.