Wall v. Wisconsin Department of Revenue

The Department of Revenue appeals from a judgment reversing a decision of the Wisconsin Tax Appeals Commission which had affirmed the department's earlier determination that Thomas Wall underpaid his income taxes for the years 1982-84. The department raises three issues on appeal: (1) whether improper service deprived the circuit court of subject matter jurisdiction; (2) whether for tax purposes record title constitutes legal title; and (3) whether 100% allocation of losses to Thomas lacked "substantial economic effect."

The first issue is waived for failure to timely raise it. As to the…