MCI Telecommunications Corp. v. Department of Treasury

Petitioner appeals as of right from the Tax Tribunal’s order declaring it liable for $81,470.89 in back taxes under the use tax act, MCL 205.91 et seq.; MSA 7.555(1) et seq. We find no error and affirm.

We first note the standard for reviewing Tax Tribunal decisions involving application of the use tax. The use tax is not a property tax, Banner Laundering Co v State Bd of Tax Administration, 297 Mich 419, 427; 298 NW 73 (1941). Accordingly, the present case is not governed by the standard of review set forth in the last sentence of Const 1963, art 6, § 28, which applies solely to cases…