Opinion No. Oag 25-85, (1985)

MICHAEL LEY, Secretary Department of Revenue

You ask a series of questions relating to whether the State of Wisconsin may constitutionally impose its general sales and use taxes, section 77.51 et seq, Stats., on reservation sales to non-tribal members by Indian retailers of certain taxable goods and services, particularly sales of cigarettes and admissions to bingo and other entertainment events. You also pose a number of questions concerning what enforcement procedures the department may employ in the event a delinquent tax liability is assessed against an Indian retailer.

For purposes of this…