glue
town
oak
creek
argued
march
decided
june
george
lines
willet
spooner
louis
quarles
milwaukee
plaintiff
error
killilea
walter
drew
milwaukee
defendant
error
justice
pitney
delivered
opinion
judgment
brought
writ
error
entered
circuit
milwaukee
county
upon
mandate
state
wisconsin
issued
reversal
previous
judgment
circuit
action
brought
plaintiff
error
recover
sum
paid
protest
part
tax
assessed
levied
taxing
authorities
state
upon
plaintiff
income
year
chapter
wisconsin
laws
overruled
plaintiff
contention
portion
tax
controversy
imposed
upon
income
derived
plaintiff
interstate
commerce
amounted
burden
upon
commerce
contravening
commerce
clause
section
article
constitution
ann
cas
sole
question
presented
consideration
act
passed
authority
amendment
state
constitution
income
tax
cases
imposes
tax
upon
incomes
received
year
ending
december
annually
thereafter
defines
term
including
rent
real
estate
interest
derived
money
loaned
invested
notes
mortgages
bonds
evidences
debt
wages
salaries
like
dividends
profits
derived
stock
purchase
sale
property
acquired
within
three
years
previous
business
whatever
royalties
derived
possession
use
franchises
legalized
privileges
income
derived
source
except
exempted
provision
person
engaged
business
within
without
state
shall
respect
income
derived
rentals
stocks
bonds
securities
evidences
indebtedness
taxed
upon
proportion
income
derived
business
transacted
property
located
within
state
determined
particular
manner
specified
section
far
applicable
corporations
allowed
make
certain
deductions
gross
income
including
amounts
paid
personal
services
officers
employes
ordinary
expenses
paid
income
maintenance
operation
business
property
including
reasonable
allowance
depreciation
losses
compensated
insurance
otherwise
taxes
etc
need
mentioned
beyond
saying
intent
necessary
effect
act
tax
gross
receipts
net
income
stipulated
facts
appears
tax
question
imposed
upon
plaintiff
net
income
accord
construction
act
adopted
state
cases
state
ex
rel
manitowoc
gas
wisconsin
tax
commission
glue
oak
creek
present
case
ann
cas
state
ex
rel
bundy
nygaard
order
determine
part
income
corporation
engaged
business
within
without
state
derived
rentals
stocks
bonds
securities
etc
taxed
derived
business
transacted
property
located
within
state
reference
formula
prescribed
another
statute
section
subsec
par
wisconsin
stats
apportioning
capital
stock
foreign
corporations
gross
business
dollars
corporation
state
added
value
dollars
property
state
made
numerator
fraction
denominator
consists
total
gross
business
dollars
corporation
within
wit
state
added
value
dollars
property
within
without
state
resulting
fraction
taken
income
tax
law
representing
proportion
income
deemed
derived
business
transacted
property
located
within
state
formula
applied
apportioning
plaintiff
net
income
year
upon
portion
thus
attributed
state
plus
income
rentals
stocks
bonds
tax
question
levied
plaintiff
corporation
organized
laws
state
wisconsin
principal
office
place
business
town
oak
creek
conducted
extensive
manufacturing
plant
selling
products
throughout
state
foreign
countries
net
income
year
exclusive
derived
rentals
stocks
bonds
making
deductions
allowed
act
amounted
derived
following
sources
goods
sold
customers
within
state
delivered
factory
goods
sold
customers
outside
state
delivered
factory
goods
sold
customers
outside
state
sales
made
goods
shipped
plaintiff
branches
goods
manufactured
plaintiff
factory
shipped
sale
said
branches
goods
sold
customers
outside
state
sales
made
goods
shipped
plaintiff
branches
without
state
goods
purchased
plaintiff
outside
state
shipped
plaintiff
factory
state
thence
shipped
sale
factory
branches
goods
sold
outside
state
sales
made
goods
shipped
said
branches
goods
purchased
plaintiff
outside
state
shipped
points
purchase
branches
without
coming
state
wisconsin
contention
made
taxability
income
designated
item
plaintiff
contention
items
taxable
derived
property
located
business
transacted
within
state
upheld
state
courts
thus
controversy
narrowed
contention
overruled
items
taxable
derived
interstate
commerce
stated
concisely
question
whether
state
levying
general
income
tax
upon
gains
profits
domestic
corporation
may
include
computation
net
income
derived
transactions
interstate
commerce
without
contravening
commerce
clause
constitution
settled
state
may
directly
burden
interstate
commerce
either
taxation
otherwise
tax
indirectly
affects
profits
returns
commerce
within
rule
thus
declared
postal
tel
cable
adams
sup
ed
settled
way
duties
laid
transportation
subjects
interstate
commerce
receipts
derived
therefrom
occupation
business
carrying
tax
levied
state
interstate
commerce
taxation
amounts
regulation
commerce
sustained
property
state
belonging
corporation
whether
foreign
domestic
engaged
foreign
interstate
commerce
may
taxed
tax
may
imposed
corporation
account
property
within
state
may
take
form
tax
privilege
exercising
franchises
within
state
ascertainment
amount
made
dependent
fact
value
property
situated
within
state
exaction
therefore
susceptible
exceeding
sum
whic
might
leviable
directly
thereon
payment
made
condition
precedent
right
carry
business
enforcement
left
ordinary
means
devised
collection
taxes
atlantic
tel
philadelphia
sup
upon
review
numerous
previous
cases
laid
certain
propositions
established
among
immunity
individual
corporation
engaged
interstate
commerce
state
regulation
prevent
state
imposing
ordinary
property
taxes
upon
property
situs
within
territory
employed
interstate
commerce
franchise
corporation
although
franchise
business
interstate
commerce
part
property
subject
state
taxation
provided
least
franchise
derived
see
also
louis
railway
arkansas
sup
yet
obvious
taxes
imposed
upon
property
franchises
employed
interstate
commerce
must
paid
net
returns
commerce
diminish
sense
diminished
tax
imposed
upon
net
returns
distinction
direct
indirect
burdens
particular
reference
comparison
tax
upon
gross
returns
carriers
interstate
commerce
general
income
tax
imposed
upon
inhabitants
incidentally
affecting
carriers
engaged
commerce
subject
consideration
phila
steamship
pennsylvania
sup
ed
justice
bradley
said
corporate
franchises
property
business
income
corporations
created
state
may
undoubtedly
taxed
state
imposing
taxes
care
taken
interfere
hamper
directly
indirection
interstate
foreign
commerce
matter
exclusively
within
jurisdiction
federal
government
many
previous
cases
referred
correct
line
distinction
well
illustrated
two
cases
decided
present
term
hardly
need
go
crew
levick
pennsylvania
sup
ed
held
state
tax
upon
business
selling
goods
foreign
commerce
measured
certain
percentage
gross
transactions
commerce
necessary
effect
tax
upon
commerce
time
duty
upon
exports
contrary
sections
article
constitution
since
operated
lay
direct
burden
upon
every
transaction
withholding
use
state
part
every
dollar
received
hand
peck
lowe
collector
sup
ed
decided
may
last
held
income
tax
act
october
stat
carried
effect
imposing
assessment
upon
entire
net
income
corporation
approximately
threefourths
derived
export
goods
foreign
countries
amount
laying
tax
duty
articles
exported
within
meaning
article
cl
constitution
distinction
direct
indirect
burden
way
tax
duty
developed
shown
income
tax
laid
generally
net
incomes
income
exportation
source
way
discrimination
laid
income
affecting
net
receipts
exportation
expenses
paid
losses
adjusted
recipient
income
free
use
chose
indirect
burden
difference
effect
tax
measured
gross
receipts
one
measured
net
income
recognized
decisions
manifest
substantial
affords
convenient
wo
kable
basis
distinction
direct
immediate
burden
upon
business
affected
charge
indirect
dental
tax
upon
gross
receipts
affects
transaction
proportion
magnitude
irrespective
whether
profitable
otherwise
conceivably
may
sufficient
make
difference
profit
loss
diminish
profit
impede
discourage
conduct
commerce
tax
upon
net
profits
deterrent
effect
since
arise
unless
gain
shown
expenses
losses
tax
heavy
unless
profits
large
tax
imposed
upon
net
incomes
whatever
source
arising
method
distributing
cost
government
like
tax
upon
property
upon
franchises
treated
property
discrimination
interstate
commerce
either
admeasurement
tax
means
adopted
enforcing
constitutes
one
ordinary
general
burdens
government
persons
corporations
otherwise
subject
jurisdiction
exempted
federal
constitution
happen
engaged
commerce
among
hold
wisconsin
income
tax
law
applied
plaintiff
case
us
deemed
direct
burden
upon
plaintiff
interstate
business
amount
unconstitutional
interference
regulation
commerce
among
measured
gross
receipts
net
proceeds
part
plaintiff
business
along
like
imposition
upon
income
derived
sources
way
corporations
business
within
state
taxed
upon
proportion
income
derived
business
transacted
property
located
within
state
whatever
nature
business
judgment
affirmed
chief
justice
white
concurs
result