W. R. Arthur & Co. v. Department of Taxation

The legislature recognized that there would be difficulties in apportioning the taxes of a unitary business which operates partly in Wisconsin and partly outside this state. A “unitary” business is one which functions as a single unit; that is, it is not divided into a separate entity for each of the states in which it operates. The legislature also recognized that no fixed formula would fairly fit all the multitudinous types of business. Accordingly, it gave a broad mandate to the Department of Taxation in sec. 71.07 (5), Stats., to prescribe rules to fit those cases which do not fall within…