Minnesota Energy Resources Corp. v. Commissioner of Revenue

by
Minnesota Energy Resources Corporation (MERC) challenged the Commissioner of Revenue’s 2008 to 2012 valuation of its natural-gas pipeline distribution system. After a trial, the Commissioner determined (1) for each of the years from 2008 to 2011, the market value of MERC’s property was lower than the Commissioner’s valuation; and (2) for 2012, the Commissioner undervalued MERC’s pipeline distribution system. Both MERC and the Commissioner appealed. The Supreme Court reversed in part, holding (1) the tax court’s explanation of the beta factors it used to calculate MERC’s cost of equity was insufficient; and (2) the tax court evaluated MERC’s evidence of external obsolescence under the wrong legal standard. Remanded. View "Minnesota Energy Resources Corp. v. Commissioner of Revenue" on Justia Law