Court of Appeals of Wisconsin August 7, 1986, 85-0700 (Tracy v. Wisconsin Department of Revenue)

EICH, J.

Donald and Shirley Tracy appeal from a judgment affirming an order of the Tax Appeals Commission. The commission dismissed the Tracys’ petition to overturn assessments of income tax liability made by the Department of Revenue for the years 1980,1981 and 1982. The trial court also ruled that the judicial review proceedings brought by the Tracys were frivolous within the meaning of sec.