Apex Laboratories International Inc v. City of Detroit

CourtMichigan Court of Appeals
DecidedJanuary 4, 2024
Docket363984
StatusUnpublished

This text of Apex Laboratories International Inc v. City of Detroit (Apex Laboratories International Inc v. City of Detroit) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Apex Laboratories International Inc v. City of Detroit, (Mich. Ct. App. 2024).

Opinion

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

APEX LABORATORIES INTERNATIONAL, UNPUBLISHED INC., January 4, 2024

Petitioner-Appellee,

v No. 363984 Tax Tribunal CITY OF DETROIT, LC No. 16-000724-TT

Respondent-Appellant.

Before: RIORDAN, P.J., and MURRAY and M. J. KELLY, JJ.

PER CURIAM.

In this income-tax dispute, respondent, the city of Detroit, appeals as of right the Tax Tribunal’s order granting in part Detroit’s motion for reconsideration, while also granting summary disposition in favor of petitioner, Apex Laboratories International, Inc. For the reasons provided below, we reverse and remand to the Tax Tribunal for further proceedings.

I. BACKGROUND

This case arises out of Detroit’s attempt to assess and collect income tax from Apex for the period covering May 1, 2012, through April 30, 2013, and returns to this Court for a third time. The pertinent background is summarized in this Court’s initial opinion, Apex Labs Int’l, Inc v Detroit, unpublished per curiam opinion of the Court of Appeals, issued May 17, 2018 (Docket No. 338218) (Apex I), pp 1-3, vacated 503 Mich 1034 (2019):

A Detroit-based private equity firm, Huron Capital Partners LLC (Huron), solicited investors to acquire partnership interests in a limited partnership, The Huron Fund II, LP (the Fund), which in turn was to acquire shares in existing “lower middle-market” companies. The general partner of the Fund was an entity known as Huron Capital Partners GP II, LLC (the general partner); however, the business operations of the general partner and the Fund were carried out by Huron.

In 2006, Huron recommended that the Fund acquire shares in (as well as debt of) Labstat International, ULC (Labstat), a Canadian company, for eventual

-1- sale. As part of the transaction, Apex was incorporated as a Delaware corporation for the sole purpose of holding the shares of Labstat to be acquired by the Fund— Apex never possessed or acquired any other assets. Although Apex possessed a Detroit mailing address, it did not have any employees, owned no real or personal property, provided no services, and sold no goods, either in Detroit or elsewhere. Various members and employees of Huron were appointed to Apex’s board of directors. Apex never held a board meeting.

Apex earned dividend income from its shares of Labstat in 2010, and paid those dividends to the limited partners of the Fund. Apex paid 1% Detroit city income tax (approximately $70,000) in 2010. In 2012, Apex sold its Labstat shares to a Canadian corporation. According to the securities purchase agreement governing the sale, the closing was to be conducted in the city of Waterloo, in Ontario, Canada. Apex realized significant capital gains from the sale, in the amount of approximately $36 million (Canadian). Apex again paid 1% ($319,000 (U.S.)) in city income tax to Detroit in 2012.

In 2015, Apex received a proposed assessment from Detroit indicating that Detroit had conducted an audit and had determined that Apex had miscalculated the income tax it owed for the 2010 and 2012 tax years. Detroit assessed Apex an additional $3,280.48 in tax, interest, and penalties for the 2010 tax year, and an additional $401,165.51 for the 2012 tax year. Apex objected on the ground that it did not conduct business within the city of Detroit and lacked the required nexus necessary for the assessment of taxes by Detroit. Apex requested a refund of the taxes paid for the 2010 and 2012 tax years. Detroit denied the request. Apex appealed that decision to the Tribunal in 2016.

The parties filed cross-motions for summary disposition under MCR 2.116(C)(10); the dispositive issue was whether Apex possessed the requisite constitutional “nexus” with Detroit to render it subject to Detroit’s taxing authority. Apex argued in the alternative that it was exempt from city income tax as a qualifying financial institution, and that if it was liable for taxation, its income should be subject to apportionment. Following a hearing on the parties’ motions, the Tribunal issued a written opinion and order granting Apex’s motion, denying Detroit’s motion, and ordering that a refund of taxes, interest, and penalties paid by Apex be issued.

The Tribunal held that Apex did not “do business” in Detroit within the meaning of the city income tax act, MCL 141.501 et seq., because, although Apex was “doing business” under MCL 141.605, it was not doing business in Detroit; in other words, Apex lacked the constitutional “nexus” with Detroit to be subject to taxation. The Tribunal held that Detroit had not established that Apex (1) had a “commercial domicile” within the city or (2) had sufficient “physical presence” in the city to establish such a nexus. The Tribunal also rejected Detroit’s “unitary business group” theory on the ground that it was an “apportionment concept and not a method to determine nexus.” The Tribunal did not address Apex’s alternative argument.

-2- Detroit appealed, and this Court affirmed the tribunal’s decision. Apex I, unpub op at 1, 6. Although the issues before this Court involved the tribunal’s decisions on competing motions for summary disposition, this Court employed the “multifaceted” standard of review for appeals from the Tax Tribunal, stating:

“If fraud is not claimed, this Court reviews the Tax Tribunal’s decision for misapplication of the law or adoption of a wrong principle. We deem the Tax Tribunal’s factual findings conclusive if they are supported by competent, material, and substantial evidence on the whole record. But when statutory interpretation is involved, this Court reviews the Tax Tribunal’s decision de novo.” [Id. at 3, quoting Briggs Tax Serv, LLC v Detroit Pub Schs, 485 Mich 69, 75; 780 NW2d 753 (2010).1]

While affirming, this Court repeatedly relied on this general, highly deferential standard of review, where reversal is only warranted when the tribunal misapplied the law, adopted a wrong legal principle, or made factual findings that were not supported by competent, material, and substantial evidence. See Apex I, unpub op at 4-6.

After this Court issued its decision in Apex I, the United States Supreme Court decided South Dakota v Wayfair, Inc, 585 US ___; 138 S Ct 2080; 201 L Ed 2d 403 (2018), which overruled Quill Corp v North Dakota ex rel Heitkamp, 504 US 298; 112 S Ct 1904; 119 L Ed 2d 91 (1992), and Nat’l Bellas Hess, Inc v Dep’t of Revenue of Illinois, 386 US 753; 87 S Ct 1389; 18 L Ed 2d 505 (1967). The day after Wayfair was decided, Detroit filed its application for leave to appeal in our Supreme Court. In Apex Labs Int’l Inc v Detroit, 504 Mich 1034 (2019) (Apex II), our Supreme Court, in lieu of granting leave to appeal, vacated Apex I and remanded to this Court for reconsideration in light of Wayfair.

On remand, this Court determined that “under the circumstances of this case, remand is required for the Tribunal to address the impact of Wayfair and the overruling of Quill and Bellas Hess, and if necessary, to address Apex’s alternative arguments.” Apex Labs Int’l, Inc v Detroit (On Remand), 331 Mich App 1, 9; 951 NW2d 45 (2020) (Apex III). This Court therefore vacated the tribunal’s judgment granting summary disposition in favor of Apex and remanded to that agency “to allow the parties to focus their arguments concerning Wayfair, Quill, and the Due Process and Commerce Clauses, and to allow the Tribunal to make a ruling in the first instance.” Id. at 10.

On remand to the Tax Tribunal, both parties filed supplemental briefs addressing Wayfair and Apex’s potential nexus with Detroit, and both parties filed competing motions for partial summary disposition.

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Apex Laboratories International Inc v. City of Detroit, Counsel Stack Legal Research, https://law.counselstack.com/opinion/apex-laboratories-international-inc-v-city-of-detroit-michctapp-2024.