Department of Revenue v. Nagle-Hart, Inc.

Initially, in its brief before the state tax appeals commission, the department took the position that the expenses involved were disallowed as being “contrary to public policy.” The fact that such construction, based on such determination by the department of an appropriate public policy, was of long-standing and not countermanded by legislative enactment was contended to mean that “governmental authority in Wisconsin has displayed a clearly defined policy.” This public policy argument was abandoned by the department on its appeal to the circuit court, and on this appeal to our court. It is…