Cited by

See Skelly Oil Co. v. Comm’r of Tax’n, (explaining that opinions must be read in light of “the specific controversy then before [the] court”); (holding that appellate decisions are not authority on issues that were “never raised or called to the attention of the court”).

And assumptions underlying an opinion that are not the subject of a court’s analysis are not precedential on the point that is assumed.” (citing Skelly Oil Co. v. Comm’r of Taxation, )).

Opinions must be read in light of “the specific controversy then before [the] court,” Skelly Oil Co. v. Comm’r of Tax’n, and appellate decisions are not authority on issues that were “never raised or called to the attention of the court,”

See, e.g., Skelly Oil Co. v. Comm’r of Tax’n, (pre-Franson decision holding that opinions must be read in light of “the specific controversy then before [the] court”); (pre-Franson decision holding that appellate decisions are not authority on issues that were “never raised or called to the

light of the issues presented.’” Skelly Oil Co. v. Comm’r of Tax’n, (quoting Sinclair v. United States, 279 U.S. 749, 767 (1929)).

But “the language used in an opinion must be read in the light of the issues presented.” Skelly Oil Co. v. Comm’r of Tax’n, (quotation omitted).

See Minn. Stat. § 518.0705(a); see also Skelly Oil Co. v. Comm’r of Tax’n, (noting that opinions must be read in light of the issue presented for decision).

See Skelly Oil Co. v. Commissioner of Tax’n, (stating that opinions must be read in light of “the specific controversy then before this court”); (stating that opinions are not precedential on issues “never raised or called to the attention of the court”).

Sorenson v. Options Residential, Inc. , see also Skelly Oil Co., v. Comm’r of Taxation, (“As [the Supreme Court] said in Sinclair v. United States, 279 U.S. 749, 767, 49 S. Ct. 471, 477, 73 L.Ed.

See Skelly Oil Co. v. Commissioner of Taxation , 269 Minn. 351 , , 645 (1964) (stating that opinions must be read in light of "the specific controversy then before this court"); Chapman v. Dorsey , 230 Minn. 279 , , 443 (1950) (stating that opinions are not precedential on issues "never raised or called to the attention of the court").

And assumptions underlying an opinion that are not the subject of a court’s analysis are not precedential on the point that is assumed” (citing Skelly Oil Co. v. Comm’r of Taxation, ); see Peterson v. Holiday Recreational Indus., Inc., n.1 (Minn. App. 2007), review denied (Minn. Feb.

Skelly Oil Co. v. Comm’r of Taxation , 269 Minn. 351, 371

See Shelly Oil Co, v. Comm’r of Taxation, 269 Minn. 351, 371

See Skelly Oil Co. v. Commissioner of Taxation, 269 Minn. 351, 371 , (stating that opinions must be read in light of “the specific controversy then before this court”); Chapman v. Dorsey, 230 Minn. 279, 288 , (stating that opinions are not precedential on issues “never raised or called to the attention of the court”).'

See Skelly Oil Co. v. Comm’r of Taxation, 269 Minn. 351, 371, (stating that “the language used in an opinion must be read in light of the issues presented” (quotation omitted)).

See also Skelly Oil Co. v. Comm’r of Taxation, 269 Minn. 351, 371, (stating that “the language used in an opinion must be read in the light of the issues presented” (quotation omitted)); Chapman v. Dorsey, 230 Minn. 279, 288, (stating that supreme court decisions implicating an issue that was not raised and addressed are

See Shelly Oil Co. v. Commissioner of Taxation, 269 Minn. 351, 371 , (stating that opinions must be read in light of “the specific controversy then before court”); Chapman v. Dorsey, 230 Minn. 279, 288 , (stating that opinions are not prece-dential on issues “never raised or called to the attention of the court”).

See Skelly Oil Co. v. Comm’r of Taxation, 269 Minn. 351, 371 , (stating that “ ‘the language used in an opinion must be read in the light of the issues presented’” (quoting Sinclair v. United States, 279 U.S. 749, 767 , 49 S.Ct.

See Shelly Oil Co. v. Comm’r of Taxation, 269 Minn. 351, 371 , (cautioning that an opinion must be read in light of the issues presented).

Shelly Oil Co. v. Comm’r of Taxation, 269 Minn. 351, 371

See Skelly Oil Co. v. Comm’r of Taxation, 269 Minn. 351, 371 , (stating that “ ‘the language used in an opinion must be read in the light of the issues presented’ ” (quoting Sinclair v. United States, 279 U.S. 749, 767 , 49 S.Ct.

See Skelly Oil Co. v. Comm’r of Taxation, 269 Minn. 351, 371 , (stating that opinion language must be read in light of issue presented); Chapman v. Dorsey, 230 Minn. 279, 288 , (deciding appeal based on the assumption that appellate jurisdiction existed, without actually addressing whether it did, is not precedential reg

See Skelly Oil Co. v. Comm’r of Taxation, 269 Minn. 351, 371 , (stating " '[ajlways the language used in an opinion must be read in the light of the issues presented’ ”) (quoting Sinclair v. United States, 279 U.S. 749, 767 , 49 S.Ct.

Relators argued that Shelly Oil Co. v. Comm’r of Taxation, 269 Minn. 351 , controlled and required the tax court to conclude that APC and AOC are not in a unitary relationship.

See Shelly Oil Co. v. Comm’n of Taxation, 269 Minn. 351, 371 , (stating “‘[a]lways the language used in an opinion must be read in the light of the issues presented’ ”) (quoting Sinclair v. United States, 279 U.S. 749, 767 , 49 S.Ct.

Nor is there any indication in the record that the tax imposed here creates a multiple burden “offensive to common concepts of what constitutes fairness.” Skelly Oil Co. v. Commissioner of Taxation, 269 Minn. 351, 368

of Taxation, 269 Minn. 351 , 131 N. W. (2d) 632 .

of Taxation, 269 Minn. 351 , 131 N. W. (2d) 632 , the taxpayer was a foreign corporation engaged in the production business wholly outside Minnesota and in the marketing business outside and within the state.

of Taxation, 269 Minn. 351 , 131 N. W. (2d) 632 , handed down since the filing of the original briefs in this case, is applicable because, according to taxpayer, it “thwarts the attempts of the Minnesota Department of Taxation, aided and abetted by the Board of Tax Appeals, to reach income which was clearly earned outside of Minnesota.” We cann