No. 82-396.

116 Wis.2d 40 (1983)

341 N.W.2d 397

MIDLAND FINANCIAL CORPORATION, Petitioner-Respondent, v. Wisconsin DEPARTMENT OF REVENUE, Appellant-Petitioner.

Supreme Court of Wisconsin.

Decided December 29, 1983.

Attorney(s) appearing for the Case

For the appellant-petitioner the cause was argued by John C. Murphy, assistant attorney general, with Bronson C. La Follette, attorney general, on the briefs.

For the petitioner-respondent there was a brief by Gerald S. Walsh, David C. Keating and Walsh and Nohr, Milwaukee, and oral argument by Gerald S. Walsh.


This is a review of a court of appeals decision affirming a judgment of the circuit court for Milwaukee county, Hon. Patrick T. Sheedy, circuit judge. The circuit court judgment reversed a decision and order of the Wisconsin Department of Revenue assessing additional corporate franchise taxes against Midland Financial Corporation. There are three questions on this review: 1) Is dividend income received by a bank holding company and deductible from gross income...

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