Kelvinator, Inc. v. Department of Treasury

This consolidated appeal (#67473 and #67474 were consolidated with #67472) comes to this Court on an appeal as of right from the October 1, 1982, Tax Tribunal order denying petitioners’ motion for summary judgment and sua sponte granting such in favor of respondent. The three cases involved here were consolidated below and involve the same issues. The original petitions of each petitioner contested several issues; however, all but the three issues presented in this appeal have been settled. Each petitioner herein received an assessment, following an audit, for taxes due for the years 1976 and…