IANATP but ---
Agree. The general rule is that states will impose a tax on income that is sourced to the state. That could be a business, rental activity, or capital gains from the sale of tangible or real property in the state. Some states are also aggressive and will withhold a percentage of gross sales of real estate when seller is a non-resident, so you might want to file for a refund, even if you have little or no capital gain income. Also, many states will provide a tax credit to residents when state income tax is liable both to the non-resident state and the resident state. They probably will want to see a Wis return to prove any tax paid to Wis for this credit, so that's another reason to file.
Another thing is, I believe Wis uses the so-called "Nebraska" rule, which means that your tax liability is determined by determining what your tax would be if all your income was taxable, then applying the ratio of Wis source income to total income to determine the tax due.
So bottom line, if you paid no tax to Wis (withholding or estimated) and didn't exceed the Wis minimum income requirement then no return.
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