Bacon v. Wisconsin Department of Revenue

The Wisconsin Department of Revenue appeals from a judgment and an order vacating a decision of the Wisconsin Tax Appeals Commission upholding a 1978 assessment against Glenn A. Bacon for additional taxable income for the year 1971. The primary issue before us is whether the assessment was barred by the four-year limitation period under sec. 71.11(21) (bm), Stats.,1 or authorized by secs. 71.11(21) (g)22 and 71.11 (21m).3 We hold that secs. 71.11(21) (g) 2 and 71.11 *16(21m) were intended to extend the period for state assessments if the taxpayer fails to notify the Department within ninety days…