Detroit Bank & Trust Co. v. Department of Treasury

Respondent, Michigan Department of Treasury, appeals as of right from a December 8, 1983, judgment of the Michigan Tax Tribunal canceling an income tax assessment against petitioner, Detroit Bank & Trust Company. We affirm.

The issue in this appeal concerns the treatment for income tax purposes of petitioner’s losses from participating in out-of-state partnerships trusts. In 1974, petitioner, a Michigan banking corporation, agreed to become an equity lender in a leveraged-lease transaction involving the National Railroad Passenger Corporation (Amtrak). Amtrak wished to purchase 110 diesel…