Detroit Hilton Ltd. Partnership v. Department of Treasury

We are called upon to answer two questions in this case: (1) whether a business taxpayer’s failure to file a "final” tax return upon the transfer of its business to a new corporate entity renders the former business owner liable, under the Sales and Use Tax Acts, for the taxes incurred by its successor in business, and (2) whether, on the facts of this case, this petitioner is equitably estopped from denying that it is liable for the taxes in question.

Our answer to both questions is no.

I

Petitioner Hilton is a limited partnership that owns a hotel building located at 1565 Washington Boulevard…