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NCR CORP. v. REVENUE DEPT.

No. 84-2010.

128 Wis.2d 442 (1986)

384 N.W.2d 355

NCR CORPORATION, Petitioner-Appellant, v. DEPARTMENT OF REVENUE, Respondent.

Court of Appeals of Wisconsin.

Decided January 10, 1986.

Attorney(s) appearing for the Case

For the appellant the cause was submitted on the briefs of Quarles & Brady, with Thomas J. Donnelly, John A. Hazelwood, Mark E. Sanders, and David D. Wilmoth of counsel, of Milwaukee.

For the respondent the cause was submitted on the briefs of Bronson C. La Follette, attorney general, with Gerald S. Wilcox, assistant attorney general of counsel, of Madison.

Before Moser, P.J., Wedemeyer and Sullivan, JJ.

WEDEMEYER, J.

NCR Corporation (NCR) appeals from a judgment affirming a Wisconsin Tax Appeals Commission (Commission) decision denying NCR a deduction on its state corporate franchise tax return for federal income taxes paid for the years 1975, 1976, 1977, 1978, and 1980.1 NCR contends that the Commission's interpretation of sec. 71.04(3), Stats. (1975), to disallow the deduction was erroneous as a matter of law. NCR further argues that...

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