Wisconsin Code § 76.46

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(1) The department may,
whenever in its opinion such action is necessary, examine or
cause to be examined the books and records of any railroad company or car line company in order to verify the accuracy of the reports submitted to the department.
(2) If any railroad company defined in s. 76.02, or any car line
company defined in s. 76.39, refuses or neglects to make any reports required under subch. I, or refuses or neglects to permit an
examination of its books and records, accounts and papers, when
requested so to do by the department, or refuses or neglects to appear before the department in obedience to its summons, it shall
be estopped to question or impeach the action or determination of
the department, or validity of any assessment made by the
department.
(3) No such company shall be allowed in any action or proceeding to question the assessment and taxation of its property as
determined by the department, unless it has made and filed with
such department a full and complete report of the facts and information prescribed by law and called for by the department.

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