Roehl Transport, Inc. v. Wisconsin Division of Hearings & Appeals

Roehl Transport, Inc., a large interstate trucking firm based in Wisconsin, challenged the imposition and collection of state taxes on fuel used by its truck fleet. Roehl claimed that fuel consumed while its trucks are idling in excess of eight minutes is not taxable and that the Wisconsin Department of Transportation lacks authority to collect taxes on behalf of two neighboring states. The parties agreed to have Roehl's challenge heard and determined by a hearing examiner in the Division of Hearings and Appeals, 1 rather than by the department, as is usually the case. 2 The examiner ruled…