Department of Taxation v. Blatz Brewing Co.

The first question is whether Blatz is “engaged in business” within and without the state within the meaning of sec. 71.07 (2), Stats., for 1945 and 1947. The department contends this means “doing business” and the apportionment of income can only apply between the particular states in which the taxpayer is “doing business” to exempt from the Wisconsin income tax that portion of the net income which is derived from business conducted outside the state. Blatz contends this concept of “doing business” is too narrow a construction of the statute and it is doing business in a tax sense by its…