Apcoa, Inc v. Department of Treasury

Petitioners appeal from a judgment of the Tax Tribunal denying a refund of single business taxes. We affirm.

Petitioner APCOA, Inc., operated parking structures at Detroit Metropolitan Airport for petitioner Wayne County and at other sites for the City of Flint. APCOA had entered into one contract with Wayne County and into various contracts with the City of Flint.

APCOA’s contract with Wayne County lists APCOA as an independent contractor, though petitioners define the contract as a satisfaction contract. Wayne County was afforded a great deal of control over how the parking facilities were…