Greenebaum v. Department of Taxation

The controversy concerns the interpretation of sec. 71.04 (4), Stats. 1945, and sec. 71.05 (5), Stats. 1947. The material parts of the two statutes are identical, so we will refer only to the 1947 enactment. Incidentally, that has now been repealed.

“Sec. 71.05. Deductions from incomes of persons other than corporations. Persons other than corporations, in reporting incomes for purposes of taxation, shall be allowed the following deductions: . . .

“(5) Dividends, except those provided in sections 71.03 (1) (e) and 71.03 (2) (d) received from any corporation conforming to all of the requirements…