Mallo v. Wisconsin Department of Revenue

¶ 1. N. PATRICK CROOKS, J.

This case is before the court on certification from the Court of Appeals, District iy pursuant to Wis. Stat. § 809.61 (1999-2000).1 The issue we address is whether the Department of Revenue (DOR) exceeded its authority under Wis. Stat. § 70.32(2r), when it promulgated Wis. Admin. Code § Tax 18.08 (current through Wis. Admin. Register No. 535, July 2000), providing for the valuation of agricultural land for taxation purposes based on its use-value, effective January 1, 2000. After examining the plain language of the statute, we conclude that § 70.32 is unambiguous and…