Pm One, Ltd v. Department of Treasury

I must respectfully dissent, because I do not believe that the record supports the conclusion reached by the majority.

Petitioner contended that the central depository account merely served as the means for handling the client’s financial affairs. Therefore contends the petitioner, the Tax Tribunal’s determination that payments for goods and services made on behalf of its clients constituted gross receipts was an error at law. Unlike the majority, I disagree. Absent fraud, this Court’s review of a decision by the Michigan Tax Tribunal is limited to determining whether the tribunal made an…