Fradco, Inc. v. Department of Treasury

Michigan’s revenue collection act 1 provides that, when the Michigan Department of Treasury (the department) issues a final assessment of tax deficiency, a taxpayer has 35 days to appeal that adverse tax decision to the department or 90 days to appeal to the Court of Claims. 2 The act also requires that the department provide a copy of a notice of the final assessment to the taxpayer’s duly appointed representative, if one was appointed. 3 These companion cases pose the same question: Does the time within which a taxpayer must appeal a final assessment of tax deficiency begin to run when the…