GLOBE-UNION, INC. v. Department of Taxation

Globe-Union filed Wisconsin income-tax returns for the years 1950 through 1952 disclosing that it was engaged in business both within and without the state of Wisconsin. The taxpayer determined its Wisconsin income on the basis of the apportionment method described in sec. 71.07 (2), Stats. 1949. Under this statute, there is applied to apportionable income a figure obtained by averaging the ratio of Wisconsin (1) tangible property, (2) cost of manufacture, and (3) sales to the total of such elements for the entire business.

Globe-Union is a Delaware corporation with its principal office in…