F.M. Management Co. Ltd. Partnership v. Wisconsin Department of Revenue

¶ 1. F.M. Management Company Limited Partnership and F.M. Real Estate Company, LLC, appeal a circuit-court order affirming a decision by the Wisconsin Tax Appeals Commission. Wisconsin Stat. § 77.22(1) imposes "a real estate transfer fee ... on every conveyance not exempted or excluded under" Wis. Stat. §§ 77.21-77.30. The Commission upheld the Wis consin Department of Revenue's assessment of a transfer fee and penalties in connection with two transfers of real estate between F.M. Management and F.M. Real Estate. The companies contend that: (1) the transactions were exempt from the transfer…