Soo Line Railroad v. Department of Revenue

Soo Line Railroad Company appeals an order dismissing its petition for review of a June 19, 1986 decision and order of the state tax appeals commission. The circuit court concluded it lacked subject matter jurisdiction over the petition because it was not timely filed with the clerk of courts and not timely served on the department or commission as required by sec. 227.53(1), Stats. Because the commission’s decision and order was made in the course of an existing judicial proceeding to review a prior order of the commission, sec. 227.53(1) did not apply. We conclude that the circuit court had…