NCR Corp. v. Department of Revenue

NCR Corporation (NCR) appeals from a judgment affirming a Wisconsin Tax Appeals Commission (Commission) decision denying NCR a deduction on its state corporate franchise tax return for federal income taxes paid for the years 1975,1976, 1977,1978, and 1980. NCR contends that the Commission's interpretation of sec. 71.04(3), Stats. (1975), to disallow the deduction was erroneous as a matter of law. NCR further argues that, assuming arguendo that federal income taxes paid by Wisconsin corporate franchises continued to be deductible, the legislature's 1981 effort to retroactively eliminate the…