Humana MarketPoint, Inc., Relator, vs. Commissioner of Revenue, Respondent

Summary

The court held that receipts from pharmacy benefit management services are sourced to the state where the services are received, and that receipt is not limited to the taxpayer's direct customer. Because the undisputed facts showed that the services were received both by the insurer in Wisconsin and by plan members in Minnesota, and the parties stipulated that the receipts had to be sourced together, the taxpayer could not prove that all services were received outside Minnesota. The tax court therefore properly granted summary judgment to the Commissioner. No separate opinions were filed.