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CITATION PARTNERS v. WIS. DEPT. OF REVENUE

No. 2020AP1683.

985 N.W.2d 761 (2023)

2023 WI 16

CITATION PARTNERS, LLC, Petitioner-Respondent-Petitioner, v. WISCONSIN DEPARTMENT OF REVENUE, Respondent-Appellant.

Supreme Court of Wisconsin.

Opinion Filed: March 1, 2023.

Attorney(s) appearing for the Case

For the petitioner-respondent-petitioner, there were briefs filed by Frederic J. Brounder , J. Wesley Webendorfer , and DeWitt LLP, Madison. There was an oral argument by J. Wesley Webendorfer.

For the respondent-appellant, there was a brief filed by Anthony D. Russomanno , assistant attorney general, with whom on the brief was Joshua L. Kaul , attorney general. There was an oral argument by Anthony D. Russomanno, assistant attorney general.

DALLET, J., delivered the majority opinion of the Court, in which ANN WALSH BRADLEY, HAGEDORN, and KAROFSKY, JJ., joined. ROGGENSACK, J., filed a dissenting opinion, in which ZIEGLER, C.J., and REBECCA GRASSL BRADLEY, J., joined.

¶1 Wisconsin imposes a five percent tax on the sale or lease of tangible personal property, including aircraft, as well as on select services. The tax applies to the "sales price"—that is, "the total amount of consideration" paid for a sale, lease, or service, with...

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