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DEPT. OF REVENUE v. MILW. MUT. INS. CO.

No. 81-434.

105 Wis.2d 705 (1981)

314 N.W.2d 920

WISCONSIN DEPARTMENT OF REVENUE, Petitioner-Appellant, v. MILWAUKEE MUTUAL INSURANCE COMPANY, Respondent.

Court of Appeals of Wisconsin.

Decided December 23, 1981.

Attorney(s) appearing for the Case

For the petitioner-appellant the cause was submitted on the briefs of Bronson C. La Follette, attorney general, and Daniel D. Stier, assistant attorney general.

For the respondent the cause was submitted on the brief of Paul A. Pakalski, Michael T. Hart, and John F. Emanuel of Whyte & Hirschboeck, S.C., of Milwaukee.

Before Decker, C.J., Moser, P.J., and Randa, J.

DECKER, C.J.

This appeal involves the attempted imposition of Wisconsin's corporation franchise tax on income earned before the tax became effective. We conclude that the taxing statute's use of the terms "federal taxable income," "net income," and "federal income tax" creates ambiguity, and affirm rejection of the attempted taxation in this case.

Section 71.01, Stats., provides in part:

(2) Franchise tax on corporations. . . . The tax imposed by this...

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