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A Tax Court decision holding that Minnesota could not apportion a Sec. 382 limitation has been rendered final, because the appeal was judged to be untimely by Minnesota Supreme Court. The court has explained that a request for review of a final order needs to be filed within 60 days of the initial decision, and not the date to which any decision is stayed. Whether Minnesota will require taxpayers to apportion the IRC sec. 382 limit is unclear.