Union Pacific Railroad Co. v. Wisc. Dept. of Revenue

Dist. Ct. did not err in granting plaintiff-railroad’s motion for summary judgment in action alleging that defendants’ denial of plaintiff’s claimed property tax exemption for value of its custom computer software violated section 308 of Railroad Revitalization and Regulatory Reform Act. Instant Wisc. tax discriminated against rail carriers by targeting railroads, since only railroad and utilities companies were required to pay tax on their intangible property such as instant custom computer software, while Wisc. systematically exempted from its intangible property tax all other manufacturing and commercial taxpayers.