Transamerica Financial Corp. v. Department of Revenue

Three issues are presented on this appeal:(1) Is the phrase “total interest and dividends received” as set forth in sec. 71.07 (2), Stats., to be read literally as meaning all interest and dividends received, whether or not apportionable, or is the phrase to be read as including only interest and dividends received which are nonapportionable;(2) Did the circuit court exceed its jurisdiction by directing the department to promulgate an apportionment rule applicable to finance companies; and(3) Does the interpretation of sec. 71.07 (2), Stats., averred for by the department, violate the due…