E. I. duPont de Nemours and Company & Subsidiaries, Relator v. Commissioner of Revenue

Summary

The court affirmed the tax court's determination that the Commissioner satisfied the statutory burden for using an alternative apportionment method. Gross receipts from DuPont's foreign exchange contracts were qualitatively different from its principal business activities and quantitatively distorted the sales factor because they exceeded 70 percent of gross receipts while generating less than 5 percent of profits. The court held that excluding those gross receipts while including net income from the contracts fairly reflected DuPont's Minnesota-allocable income. No separate opinions were issued.