Kastengren v. Wisconsin Department of Revenue

In this case, the Tax Appeals Commission granted the Wisconsin Department of *590Revenue's motion for summary judgment determining that the purchaser of Uncle Harry's Fine Food Products, Inc. (Uncle Harry's), Robert Kastengren, is personally liable for Uncle Harry's unpaid sales and use taxes. The circuit court reversed; it concluded that the department had not directed collection against Uncle Harry's as required by Wis. Adm. Code sec. Tax 11.91(4)(a) because it had not attempted to collect the taxes from Kastengren's "predecessor" and Uncle Harry's former owner, Harry Dembroski. We conclude…