Schneider National Leasing Inc v. United States

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN SCHNEIDER NATIONAL LEASING, INC., Plaintiff and Counterclaim Defendant, v. Case No. 17-C-672 UNITED STATES OF AMERICA, Defendant and Counterclaim Plaintiff. FINDINGS OF FACT AND CONCLUSIONS OF LAW Section 4051 of the Internal Revenue Code (I.R.C.) imposes a 12 percent tax on the first retail sale of “tractors of any kind chiefly used for highway transportation in combination with a trailer or semitrailer.” 26 U.S.C. § 4051(a)(1)(E). Schneider National Leasing, Inc. (SNL), filed this action against the United States seeking a refund of…