Department of Taxation v. Pabst

The appeal and review raise one issue: Whether the trusts involved were administered in Wisconsin within the meaning of sec. 71.08 (8), Stats., in the years 1952, 1953, and 1954.

The relevant facts contained in the stipulation are as follows:

*197Both trusts are inter vivos trusts established by a trust agreement executed December 24, 1938, in Wisconsin by Ida C. Pabst, a resident of Wisconsin.

Since February 25, 1952, the trustees are Harald Pabst, a resident of Colorado, Robert E. Pabst, a resident of Connecticut, and Fred Pabst, Jr., a resident of Vermont. None of the trustees during any of the…