Watts Regulator Company v. Department of Treasury

I. INTRODUCTION

In these 23 consolidated appeals, 1 plaintiffs are taxpayers that, respectively, appeal as of right orders granting summary disposition in each case to defendant, the Michigan Department of Treasury. Each appeal raises common issues challenging the Court of Claims’ holding that the mandatory apportionment provision of the Single Business Tax Act (SBTA), former MCL 208.1 et seq., 2 impliedly repealed a provision of Michigan’s enactment of the Multistate Tax Compact (the Compact), former MCL 205.581 et seq. 3 That provision of the Compact had allowed multistate taxpayers to…