Frankenmuth Mutual Insurance v. Department of Treasury

Plaintiff appeals as of right from a September 10, 1982, Court of Claims order in favor of defendant denying plaintiffs claim for a single business tax refund in the amount of $7,885.

This case involves the construction and interplay of various sections of the Michigan Single Business Tax Act (SBTA), MCL 208.1 et seq.; MSA 7.558(1) et seq. The parties dispute the amount of tax due from plaintiff for the taxable year 1978.

The starting point for determining SBTA liability is SBTA § 9, MCL 208.9; MSA 7.558(9), which uses business income as a basis and then provides for certain additions and…