Advo-Systems, Inc v. Department of Treasury

I respectfully dissent. At first blush, it is tempting to dismiss petitioner’s claim that Mailbox Values is a periodical within the meaning of the tax code since, with the exception of the public service announcement relating to missing children on the accompanying mailing card, Mailbox Values contains nothing but a loose-leaf collection of advertising materials. However, for the reasons to be discussed below, I conclude that nothing within the tax code itself or within the general definition of the word "periodical” warrants such a conclusion.

MCL 205.94; MSA 7.555(4) contains a list of…