ZIP SORT, INC. v. DEPT. OF REVENUE

No. 00-2824.

247 Wis.2d 295 (2001)

2001 WI App 185

634 N.W.2d 99

ZIP SORT, INC., d/b/a Federal Mailing Systems, Petitioner-Appellant, v. WISCONSIN DEPARTMENT OF REVENUE, Respondent-Respondent.

Court of Appeals of Wisconsin.

Decided July 18, 2001.


Attorney(s) appearing for the Case

On behalf of the petitioner-appellant, the cause was submitted on the briefs of Kay Nord Hunt of Lommen, Nelson, Cole & Stageberg, P.A., Minneapolis, Minnesota.

On behalf of the respondent-respondent, the cause was submitted on the brief of James E. Doyle, attorney general, and Stephen J. Nicks, assistant attorney general.

Before Dykman, P.J., Vergeront and Roggensack, JJ.


¶ 1. DYKMAN, P.J.

Zip Sort, Inc., appeals from an order affirming a Tax Appeals Commission (commission) decision that Zip Sort's property is not "manufacturing property" within the meaning of WIS. STAT. § 70.995 (1993-94).1 Zip Sort first asserts that we should apply a de novo standard of review to the commission's decision because it faced a question of first impression and because...

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