Cudahy v. Tax Commission

The consideration of the validity of the additional assessment involves two distinct and separable questions : First, Was the Wisconsin Tax Commission without statutory power on May 23, 1936, to impose an additional assessment upon Michael F. Cudahy, hereinafter called the “taxpayer” ? Second, Did the transactions involved claimed by the taxpayer to be a reorganization result in taxable income to the taxpayer in 1929? Each of these matters will be treated separately.

*320Part I.

The income dealt with was the income for the year 1929. Sec. 71.11 (5), of the statutes of 1929, provided:

“Additional…