Wheeler Estate v. Department of Treasury

Respondent, the Department of Treasury, appeals an order of the Michigan Tax Tribunal that granted petitioners’ motion for summary disposition and denied respondent’s motion for summary disposition. For the reasons set forth in this opinion, we affirm.

I. FACTS AND PROCEEDINGS

Petitioners were shareholders of an S corporation called Electro-Wire Products that makes electrical systems for Ford Motor Company. Ford wanted ElectroWire to establish a worldwide presence, so in 1994 Electro-Wire acquired all the business assets of a German business, Temic Telefunken Kabelsatz, GmbH,1 which was also…