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UNITED PARCEL SERVICE CO. v. DOR,

No. 95-2493.

204 Wis.2d 63 (1996)

553 N.W.2d 861

UNITED PARCEL SERVICE CO., Petitioner-Appellant, v. WISCONSIN DEPARTMENT OF REVENUE, Respondent-Respondent.

Court of Appeals of Wisconsin.

Decided July 31, 1996.

Attorney(s) appearing for the Case

For the petitioner-appellant the cause was submitted on the briefs of David D. Wilmoth of Quarles & Brady of Milwaukee, and Richard D. Birns of Philadelphia, PA.

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

Before Dykman, Sundby and Vergeront, JJ.

VERGERONT, J.

United Parcel Service Company (UPSCO) appeals from a trial court order affirming a decision of the Wisconsin Tax Appeals Commission. The Commission upheld UPSCO's franchise tax assessments for 1985 and 1986 imposed by the Wisconsin Department of Revenue using the apportionment formula under WIS. ADM. CODE § TAX 2.46.1 UPSCO contends: (1) the apportionment formula, as applied...

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