Legal Opinion
Michigan v. United States
District Court, W.D. Michigan
Decided July 28, 1992No. 5:90-CV-35PublishedCited by 2 opinions
1Opinion of the Court
OPINION DENYING PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT AND GRANTING DEFENDANT’S MOTION FOR SUMMARY JUDGMENT
HILLMAN, Senior District Judge.
I. Introduction.
The State of Michigan and the Michigan Education Trust (the “Trust” or the “MET”) have sued the United States for refund of taxes assessed against income earned by the Trust. They seek the refund under several theories: (1) The Internal Revenue Code (“the Code”) does not apply to the Trust because the Trust is part of the State of Michigan; (2) Code Section 115(1), 26 U.S.C. § 115(1) exempts the Trust’s income from taxation; (3) The Trust…
2Cases cited18 opinions
- Baker v. CarrSupreme Court of the United States · 1962
- Garcia v. San Antonio Metropolitan Transit AuthoritySupreme Court of the United States · 1985
- Gregory v. AshcroftSupreme Court of the United States · 1991
- Davis v. Michigan Department of the TreasurySupreme Court of the United States · 1989
- Luther v. BordenSupreme Court of the United States · 1849
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3Cited by2 opinions
- Capital Gymnastics Booster Club, Inc. v. Comm'rUnited States Tax Court · 2013
- State of Mich. v. United StatesDistrict Court, W.D. Michigan · 1992