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| | No. 99-0194 |
 | | In June 1994, the railroads filed these consolidated actions in state court asserting that the retroactive assessments are invalid on a number of state law grounds and under the federal constitution, and challenging the 18% interest on any amounts not paid by July 1, 1994. |
 | | The railroads contend the 4-R reduction was not the result of "inadvertence," because it was intentional, and it was not the result of a "mistake," because the meaning of "mistake" does not include a deliberate and strategic decision, such as that which DOR made when it agreed to the 4-R reduction. |
 | | City of Green Bay, 105 Wis.2d 699, 703, 314 N.W.2d 904, 906 (1981); and the state should have the means of collecting taxes for which taxpayers are legally liable but which were not assessed, so that all taxpayers bear their fair share. |
| www.wisbar.org /res/capp/z1999/99-0194.htm (4242 words) |
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