Ford Motor Co. v. Bruce Township

Petitioner appeals as of right the dismissal of its petition for review by the Michigan Tax Tribunal (MTT) on the ground that it lacked subject-matter jurisdiction.1 We affirm.

On February 19, 2002, petitioner filed its petition for review pursuant to MCL 211.53a for recovery of excess tax payments not made under protest. It averred that, because of a mutual mistake of fact, it had paid taxes in excess of the correct and lawful amount since “Petitioner and Respondent did not realize at the time the personal property tax statements were filed that Petitioner was double reporting certain…