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PORT AFFILIATES, INC. v. DOR

No. 93-1755.

190 Wis.2d 271 (1994)

526 N.W.2d 806

PORT AFFILIATES, INC., Petitioner-Appellant, v. Wisconsin DEPARTMENT OF REVENUE, Respondent-Respondent.

Court of Appeals of Wisconsin.

Decided December 20, 1994.

Attorney(s) appearing for the Case

For the petitioner-appellant the cause was submitted on the briefs of Michael, Best & Friedrich, with Robert A. Schnur and Joseph A. Pickart, of Milwaukee.

For the respondent-respondent the cause was submitted on the briefs of James E. Doyle, attorney general, and Gerald S. Wilcox, assistant attorney general.

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

SCHUDSON, J.

Port Affiliates, Inc. (Port), appeals from the trial court judgment affirming a decision of the Wisconsin Tax Appeals Commission. The Commission affirmed a franchise tax assessment made by the Wisconsin Department of Revenue with respect to Port's taxable years 1984 through 1987. At issue in this appeal is the Department of Revenue's determination that computation of Port's apportionable income should include: (1) certain interest, dividends, and gains...

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