Although an ambiguous statute will be strictly construed against granting a deduction, strict construction does not require the narrowest possible construction or an unreasonable construction. An unambiguous tax deduction statute is not subject to a narrow construction. Wis. Tax Rptr. Wis. Tax Rptr. Wis. Tax Rptr.
Examples are patents and copyrights.
An intangible asset, the useful life of which is not limited, is not subject to the allowance for depreciation. The commission also decided that the department's disallowance of Northern's amortization of the lease purchases was undermined by its allowance of Northern's amortized transactional expenses. On appeal, the department does not specifically challenge the commission's classification of Northern's investments in the safe harbor leases as intangible assets with finite income-producing lives. There is no question that Wisconsin does not recognize safe harbor leases by this amendment. It is important to note that Northern is not attempting to depreciate for Wisconsin tax purposes the entire purchase price of approximately 50 million dollars attributable to the underlying equipment as well as the 14 million cash payment as it was allowed to deduct for federal tax purposes.