International Home Foods, Inc. v. Department of Treasury

(<dissenting). I respectfully dissent. The majority holds that “because defendant had in place an RAB [Revenue Administrative Bulletin] favorable to plaintiffs position for the tax years before the Gillette [Co v Dep’t of Treasury, 198 Mich App 303; 497 NW2d 595 (1993)] decision was released, defendant is bound by that RAB.” Ante at 358. Thus, according to the majority, defendant is prohibited from applying Gillette retroactively. However, the retroactive application of Gillette has previously been decided by this Court on the identical issues presented here. In Rayovac Corp v Dep’t of…