Rice Insulation, Inc. v. Wisconsin Department of Revenue

The Tax Appeals Commission upheld the Department of Revenue’s assessment of a use tax against Rice Insulation Company. Rice appeals from a judgment affirming the Tax Appeals Commission’s order. We affirm.

Rice bought insulation materials from a manufacturer without paying the sales tax. It gave the manufacturer resale certificates stating the materials were to be resold to a tax exempt entity. Rice then contracted to sell the materials to St. Michael Hospital for use in construction and renovation. No tax was paid on the resale because the hospital is a tax exempt entity. Sec. 77.54 (9a),…