Credit Acceptance Corp. v. Department of Treasury

I concur fully in the analysis and the results reached by the majority opinion. I write separately only to address further certain aspects of the opinion of the Tax Tribunal. Although the tribunal determined that the contracting and subsequent reimbursement of collection costs did not constitute a “sale” under § 7 of the Single Business Tax Act (SBT), MCL 208.7; MSA 7.558(7), as observed in Stratton-Cheeseman Management Co v Dep’t of Treasury, 159 Mich App 719; 407 NW2d 398 (1987), and APCOA v Dep’t of Treasury, 212 Mich App 114; 536 NW2d 785 (1995), the issue, in my judgment, is whether the…