Pabst Brewing Co. v. Wisconsin Department of Revenue

The majority concludes that whether a sale of beer is made "within this state" is determined by the residency of the purchaser. The statutory language from which the majority draws *297its conclusion reads: "Sales of tangible personal property are in this state if. . . the property is delivered . . . to a purchaser . . . within this state. . . Section 71.07(2)(c)2, Stats. To reach its conclusion, the majority construes "within this state" to modify "purchaser," and then determines that a purchaser is not within this state if he or she resides outside Wisconsin but comes to Wisconsin to buy beer.

I…