W A Foote Memorial Hospital v. City of Jackson

In these consolidated cases, petitioner appeals as of right from the Michigan Tax Tribunal’s orders dismissing petitioner’s tax appeals for lack of jurisdiction. We affirm.

I

This case presents a narrow question of statutory *335interpretation to decide whether the term “certified mail” under MCL 205.735(2) encompasses priority overnight delivery by Federal Express for the purpose of timely filing an appeal with the Michigan Tax Tribunal. We hold that the term “certified mail” refers to a classification of domestic mail provided by the United States Postal Service and therefore explicit statutory…