LaBELLE MANAGEMENT, INC v. DEPARTMENT OF TREASURY

Plaintiff appeals the trial court’s order that denied its motion for summary disposition and granted defendant’s motion for summary disposition. At issue is the interpretation of MCL 208.1117(6), which defines the term “unitary business group.” Defendant determined that plaintiff is a member of a unitary business group and taxed plaintiff accordingly for two tax periods. Plaintiff filed suit and alleged that defendant improperly broadened its interpretation of “unitary business group” beyond the scope intended by the Legislature. The trial court agreed with defendant’s interpretation. We…