Kamps V. Wisconsin Department Of Revenue

¶1. The primary issue on this appeal is whether certain of Edward Wilkinson's retirement payments are exempt from taxation under Wis. Stat. § 71.05(1)(a) (2001-02).*fn1 The Tax Appeals Commission decided they were not. Wilkinson*fn2 appeals the trial court's decision affirming the commission's ruling and order, contending that: (1) the commission erred in its construction of the statute, (2) the Department of Revenue (DOR) is equitably estopped from taxing the benefits, (3) taxation of these benefits denies his right to equal protection, and (4) the commission's decision is contrary to DOR's policy and practice.