Fulton Foundation v. Department of Taxation

Sec. 72.75 (5) (a), Stats. 1947, provided as follows:

“All property transferred to municipal corporations within the state for strictly county, town, or municipal purposes, or to corporations or voluntary associations of the state, organized under its laws, solely for religious, humane, charitable, or educational purposes, . . . which shall use such property *6exclusively for the purposes of their organisation within the state, . . . shall be exempt [from gift tax].” (Italics supplied. )

Ch. 356, Laws of 1949, repealed and then re-created such statute so as to drastically broaden the definition…