Van Susteren v. Wisconsin Department of Revenue

The majority opinion reverses the Wisconsin Tax Commission's decision without justification and contrary to the established law and facts. I dissent.

Each year (except one) for more than a decade, Urban Van Susteren filed his state income tax return late and at times filed only after persistent prodding from the Revenue Department. In 1983, a jury convicted him of willfully failing to file tax returns for the years 1979-82, the years in issue in this case. The Commission then found by clear and convincing evidence that Van Susteren intended to defeat the income tax assessment in violation of…