Giffels Associates, Inc. v. Department of Treasury

Plaintiff, Giffels Associates, Inc., filed annual reports and paid franchise fees for the years 1968 to 1971. The reports were accepted by defendant. In 1973, defendant conducted a field audit of plaintiff’s books and assessed a franchise fee deficiency of $49,585.29, including interest, for the years 1968-1971, which was paid under protest. Two years later, in Clark Equipment Co v Department of Treasury, Revenue Division, 394 Mich 396; 230 NW2d 548 (1975), the Supreme Court held that the Franchise Fee Division of the Department of Treasury was without authority to conduct field audits and…