Whitney v. Department of Taxation

The appellant’s position may be expressed as follows: Mr. Whitney, although a resident of Wisconsin and a licensed engineer, should not be taxed in Wisconsin on that portion of his income which was not derived from his personal services but which represented earnings from a business having a situs outside of Wisconsin; that it was income from a btisiness is evidenced by the fact that the firm employed a large staff, utilized a significant capital account and required less than 10 percent of Mr. Whitney’s time in professional engineering.

The respondent challenges the claim that this is a…