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DEPARTMENT OF TAXATION v. ANSUL CHEMICAL CO.

260 Wis. 96 (1951)

DEPARTMENT OF TAXATION, Appellant, vs. ANSUL CHEMICAL COMPANY, Respondent.

Supreme Court of Wisconsin.

November 6, 1951.

Attorney(s) appearing for the Case

For the appellant there were briefs by the Attorney General and Harold H. Persons and E. Weston Wood, assistant attorneys general, and oral argument by Mr. Persons and Mr. Wood.

For the respondent there was a brief by Toebaas, Hart, Kraege & Jackman of Madison, and Eastman, Rose & Faller of Marinette, and oral argument by W. L. Jackman.

BROWN, J.

The department's assessment and a portion of its argument was made upon the ground that Ansul had made sales the income from which was apportionable to Wisconsin and controlled by sec. 71.02 (3) (d) 3, Stats. 1943, but at the hearing before the board of tax appeals and its subsequent appeals it has attempted to sustain and increase the amount of its assessment upon a second theory, which is that Ansul made sales...

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