Livingstone v. Department of Treasury

We granted leave to consider whether the statute of limitations bars the majority of the alleged use tax1 sought to be assessed against the derivatively liable corporate officer, where there was no issuance of a notice of intent to assess against the officer and where the notice of final assessment was issued more than four years after a majority of the assessment and the taxable period.

We would hold that the use tax statute of limitation found in MCL 205.100(3); MSA 7.555(10)(3)2 *776has no application to derivatively liable corporate officers. Consequently, the limitation period does not bar a…