Wisconsin Department of Revenue v. United States Shoe Corp.

In this appeal, we decide that United States Shoe Corporation, under sec. 71.06(1), Stats. (1975), 1 may not offset the net business losses sustained by corporations with which it merged against its 1976 and 1977 Wisconsin net business income. We also decide that the circuit court correctly concluded that a closing agreement between the Department of Revenue and U.S. Shoe, to compromise the taxpayer's franchise tax liability under a June 19,1984 additional assessment, did not settle U.S. Shoe's franchise tax liability for fiscal years 1976 and 1977. We therefore affirm the circuit court's…