wis 77All City Communication Co. v. DOR, 2003 WI App 77, 263 Wis. 2d 394, 661 N.W.2d 845, 02-1201. 77.51 Annotation For the use tax to apply to intercompany transfers with wholly-owned77.22 Annotation A memorandum announcing a reorganization of a land-owning partnership into a limited liability company (LLC) and that the LLC was now the owner of the real estate was a