Catalina Marketing Sales Corp. v. Department of Treasury

The issue in this case is whether the Michigan Tax Tribunal and the Court of Appeals erred in holding that petitioners’ Checkout Coupon™ program, which involves both the transfer of tangible personal property and the provision of services, constitutes a sale at retail that is subject to sales tax under MCL 205.52. Respondent, the Department of Treasury, alleges that petitioners sold coupons to its manufacturer-clients and that these were sales at retail on which petitioners owe sales tax. Petitioners contend that they were selling services, not goods, and that the delivery of the…