Wilson v. Department of Treasury

Appellants are Michigan residents who own 100% of the stock of a subchapter S corporation known as the Buffalo Bills, which is a New York corporation doing business in New York and California. In 1975 and 1976, appellants filed their Michigan income tax returns and deducted from their adjusted gross income the income received by them from the subchapter S corporation. The appellee, Department of Treasury, disallowed the deductions, added them back to appellants’ gross income thereby increasing the Michigan tax due in the amount of $4,140.77, and assessed a penalty of $414.09 and interest of…