Detroit Hilton Ltd. Partnership v. Department of Treasury

Per Curiam;.

On April 14, 1977, petitioner, Detroit Hilton Limited Partnership, filed a petition with the State Board of Tax Appeals in which it contested four assessments totalling $73,960.52 imposed by respondent, Department of Treasury, Revenue Division.1 On May 14, 1981, the State Board of Tax Appeals affirmed the tax assessment, and petitioner appeals as of right.

*825A review of the record reveals the following chronology. In 1969, petitioner applied for and was granted a license to collect sales, use, and withholding taxes in connection with its ownership of the Detroit Hilton Hotel. Until…