Rosenbalm v. Department of Treasury

These two cases have been consolidated for this appeal. Both cases involve the applicability of Michigan’s intangibles tax act, MCL 205.131 et seq.; MSA 7.556(1) et seq., on distributions from subchapter s corporations to their shareholders.

Petitioners William E. Rosenbalm and Carole G. Rosenbalm appeal as of right from the Michigan Tax Tribunal’s August 1, 1986, opinion and judgment granting respondent Michigan Department of Treasury’s motion for summary disposition and denying petitioners’ motion for summary disposition.

From 1978 through 1982, William E. Rosenbalm operated Rosenbalm…