Shopper Advertiser, Inc. v. Wisconsin Department of Revenue

The taxpayer erred in filing its petition with the Rock county circuit court rather than with the Dane county circuit court. I agree with the majority opinion that there is sufficient leeway in the statutes to enable the court to save the taxpayer from *237its procedural error without doing harm to the public interest. I therefore agree with the majority opinion that the circuit court action should not be dismissed.

I do not join the majority opinion because I have difficulty following its discussion of “subject matter jurisdiction”, “competency of the court,” and “venue.”

The terms subject matter…