Owens-Illinois, Inc. v. Town of Bradley
In Owens-Illinois, Inc. v. Town of Bradley, 132 Wis. 2d 310, 392 N.W.2d 104, 105 (Wis. Ct. App. 1986) the Wisconsin Department of Revenue similarly argued that property eligible for a tax exemption should be used primarily for the purpose of waste disposal. There the statute referred to property "used for . . . the purpose of abating or eliminating pollution." Id. at 105 n.1.
Noting that the statute did not contain language requiring a "primary purpose," the court held that "the fact that the boiler and power house produce usable energy as well as dispose of wood waste does not negate its exempt status when the statute unambiguously provides that such property is exempt." Id. at 107.