Guardian Photo, Inc v. Department of Treasury

Plaintiff appeals as of right from an order granting defendant summary disposition of plaintiffs tax refund claim pursuant to MCR 2.116(C)(8). We affirm.

i

Plaintiff sought a refund of taxes it paid under the Single Business Tax Act (sbta), MCL 208.1 et seq.-, MSA 7.558(1) et seq. Plaintiff incorporated in Pennsylvania, but maintained its headquarters in North-ville, Michigan. During the 1991 tax year, plaintiff conducted a photograph processing business in eight states, including Michigan. According to plaintiffs complaint, “[p]ursuant to an Asset Purchase Agreement dated July 17, 1991,…