Carrion Corp. v. Wisconsin Department of Revenue

I dissent from the proposition that the taxpayer's sale of its business was a sale "at retail" which was subject to a retail sales tax under *278sec. 77.52(1), Stats. (1981-82).1 It is undisputed that the taxpayer sold its entire business in two transactions, effective January 17, 1983 (retail division), and February 18,1983 (commercial division). The sole reason the Tax Appeals Commission affirmed the department's denial of the taxpayer's petition for rede-termination of its sales tax liability was that the taxpayer failed to prove that after these sales, it did not continue to make sales at…