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Wisconsin Property Tax Updates

Updated March 2025

Wisconsin Tax Appeals Commission Rejects State’s Attempt To Divest It Of Jurisdiction Over Large Tax Appeals

In a decision issued on March 11, 2025, the Wisconsin Tax Appeals Commission rejected an attempt by the Wisconsin Department of Revenue to divest it of subject matter jurisdiction over a large group of manufacturing assessment appeals involving millions of dollars in value.

The jurisdictional statute (Wis. Stat. 70.995(8)(c)1) states that objections to manufacturing assessments must be made “on a form prescribed by the department of revenue that specifies that the objector shall set forth the reasons for the objection … and the basis for” the objector’s opinion of value. The appeal form the Department of Revenue created under this statute includes a section for the objector to provide these two pieces of information. That section contains two adjacent boxes, one designated for the reason for the taxpayer’s objection and the other for the basis of the taxpayer’s opinion of value.

In the appeals in question, the taxpayers’ agent had placed text encompassing both pieces of information in the first box and left the second box blank. The State argued that leaving the second box blank per se divested the Commission of subject matter jurisdiction irrespective of whether all the required information was in the other box or elsewhere on the form.

The Tax Appeals Commission firmly rejected the State’s position, holding that as long as a taxpayer provides all the information required by the statute on the Department’s form the taxpayer has satisfied the jurisdictional requirement, whether or not the taxpayer has placed text in every box. The Commission’s decision was unusually harsh, finding one of the Department of Revenue’s arguments to be “frankly ridiculous,” and admonishing the Department to “restrain itself from making such frivolous and overreaching arguments” in future cases.

The case is Badger Mining Corporation and Smart Sand, Inc v. Wisconsin Department of Revenue.

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Hansen Reynolds LLC
American Property Tax Counsel (APTC)

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