Florida Leasco, LLC v. Department of Treasury

Petitioner, Florida Leasco, LLC, appeals as of right from the Tax Tribunal’s order dismissing its petition for lack of jurisdiction. The Tax Tribunal dismissed petitioner’s appeal as untimely because it was sent by certified mail within, but received one day after, the thirty-five-day deadline set by MCL 205.22(1). We reverse.

This appeal presents an issue of statutory construction, which we review de novo. In re MCI Telecommunications Complaint, 460 Mich 396, 413; 596 NW2d 164 (1999). The only statutory provision providing any guidance with regard to what constitutes a “filing” is MCL…