Kearney & Trecker Corp. v. Department of Revenue

This is an appeal from a judgment entered on May 23, 1977, affirming a decision and order of the Wisconsin Tax Appeals Commission. The Tax Appeals Commission affirmed the action of the Department of Revenue (Department) in denying the application of Kearney & Trecker (K & T) for abatement of an assessment of additional income and franchise taxes for the fiscal years ended September 27, 1964, through October 1, 1967. The issue in this case is the tax treatment of the income which K & T received from the rental and subsequent sale of machines located outside the state of Wisconsin.

During the…