City of Racine v. Morgan

Five issues are presented:(1) Is the method to be followed in apportioning the distributable tax receipts under sec. 71.14, Stats., the “arithmetical” average method, or the “weighted” average method ?(2) Does the fact that the department has applied the arithmetical method in prior years constitute an administrative rule of long standing that is binding on the department?(3) Should the department be allowed to apply the arithmetical method in some situations and the weighted average in others ?(4) Is the department correctly apportioning the tax receipts from the income on the sec. 71.07…