North Dakota Supreme Court December 29, 1987, Civ. 11391 (Minnesota Mining & Manufacturing Co. v. Conrad)

GIERKE, Justice.

Minnesota Mining and Manufacturing Company [3M] appeals from a district court judgment upholding the State Tax Commissioner’s assessment of $27,372 in additional corporation income tax, penalty and interest against 3M for tax years 1979 through 1981, and denial of 3M’s request for a refund of $76,967 for those same years. We reverse and remand.