Holy Family Convent of Manitowoc v. Wisconsin Department of Revenue

Holy Family Convent of Manito-woc, Wisconsin, St. Camillus Health Care Center, Inc., Sacred Heart Roman Catholic Church, and St. John's De Nepomuc Roman Catholic Church (collectively, the charities) appeal from an order which determined that their residuary bequests under the will of Emily Pierron are subject to inheritance tax. The trial court determined that only $1,000 of each bequest is exempt from taxation *194under sec. 72.17(4)(c), Stats.1 The charities claim that the full amount of the residuary bequests is exempt from inheritance tax pursuant to sec. 72.15(l)(a)2, Stats.2 Because we…