Michigan National Bank v. Department of Treasury

Respondent-appellee, Michigan Department of Treasury, undertook an audit of dealings in gold and silver conducted by petitioner-appellant, Michigan National Bank, through its international division, during the period from January 1, 1977, through July 31, 1980, and assessed a sales tax deficiency against petitioner on its dealings. The tax, with interest and penalties, amounts to $46,701.55. Ninety-five percent of petitioner’s dealings involved coins, primarily South African gold Kruggerands.

Typically, when a customer of the bank sought the bank’s help in arranging for the purchase of gold,…