Reliable Stores Corp. v. City of Detroit

Plaintiff, a Maryland corporation, owning and operating chain stores in several States but not in Maryland, sells merchandise on the instalment plan. The major part of the assets of its Detroit store consists of customers ’ accounts receivable, for goods sold at such store. In 1927 and 1929 the city of Detroit levied taxes against plaintiff on such accounts. The taxes were paid under protest, and this action is to recover them. Defendant had judgment.

Counsel recognize that plaintiff is a nonresident of this State (Larson v. Dubuque Fire & Marine Ins. Co., 238 Mich. 366), and that the…