COPLAND v. DEPARTMENT OF TAXATION


16 Wis.2d 543 (1962)

COPLAND and wife, Respondents, v. DEPARTMENT OF TAXATION, Appellant.

Supreme Court of Wisconsin.

May 4, 1962.


Attorney(s) appearing for the Case

For the appellant the cause was argued by E. Weston Wood, assistant attorney general, with whom on the briefs were John W. Reynolds, attorney general, and Harold H. Persons, assistant attorney general.

For the respondents there was a brief by Aberg, Bell, Blake & Metzner of Madison, and oral argument by George G. Blake and William J. P. Aberg.


CURRIE, J.

In order to better understand the questions here presented we deem it necessary to first examine the 1947 transactions. Since the purchasers of the 75 percent interest in the old corporation paid $1,050,000, that was their tax basis in the stock acquired. None of these stockholders were residents of Wisconsin, and the ensuing transactions were conducted with little, if any, regard for Wisconsin law. Apparently, the plan was to write up the corporation's...

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