Briggs & Stratton Corp. v. Department of Taxation

The parties agree that the question for decision is as follows: Is the income received by the taxpayer corporation from its intangibles, securities which were physically located in Wisconsin all during the period involved, subject to taxation in Wisconsin under the applicable statutes ? The Wisconsin Department of Taxation, hereinafter referred to as the “department,” assessed the income. The board of tax appeals set aside the assessment. The circuit court affirmed the decision of the board of tax appeals.

The material facts may be stated as follows: The respondent is a Delaware corporation…