Sav-Time Inc v. Department of Treasury

CourtMichigan Court of Appeals
DecidedMarch 10, 2026
Docket370459
StatusPublished

This text of Sav-Time Inc v. Department of Treasury (Sav-Time Inc v. Department of Treasury) 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
Sav-Time Inc v. Department of Treasury, (Mich. Ct. App. 2026).

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

SAV-TIME, INC., FOR PUBLICATION March 10, 2026 Plaintiff-Appellant, 11:50 AM

v No. 370459 Court of Claims DEPARTMENT OF TREASURY, LC No. 21-000186-MT

Defendant-Appellee.

Before: RICK, P.J., and MALDONADO and KOROBKIN, JJ.

RICK, P.J.

Plaintiff, Sav-Time, Inc. (Sav-Time), appeals as of right an opinion and order granting summary disposition in favor of defendant, the Department of Treasury (the Department), under MCR 2.116(C)(10) (no genuine issue of material fact), and denying Sav-Time’s countermotion for summary disposition under MCR 2.116(C)(10) and MCR 2.116(I)(2) (opposing party entitled to summary disposition). We affirm.

This appeal arises from the Department’s audit of Sav-Time’s sales, use and withholding (SUW) tax returns for the years 2015 through 2018. We are primarily asked to determine whether the Court of Claims properly determined that Sav-Time failed to properly itemize labor charges in its financial documents and data, and that Sav-Time’s documents contained inaccurate and inconsistent dollar amounts in a variety of sales categories. However, because the proper resolution of this case rests largely on the correct interpretation of certain portions of the General Sales Tax Act (GSTA), MCL 205.51 et seq., we will first set forth the relevant statutes and rules before addressing the factual and procedural history of the case.

I. LEGAL BACKGROUND

As stated, this matter is generally governed by the GSTA. MCL 205.52 of the GSTA provides, in relevant part:

(1) Except as provided in section 2a, there is levied upon and there shall be collected from all persons engaged in the business of making sales at retail, by which ownership of tangible personal property is transferred for consideration, an

-1- annual tax for the privilege of engaging in that business equal to 6% of the gross proceeds of the business, plus the penalty and interest if applicable as provided by law, less deductions allowed by this act.

* * *

(3) Any person engaged in the business of making sales at retail who is at the same time engaged in some other kind of business, occupation, or profession not taxable under this act shall keep books to show separately the transactions used in determining the tax levied by this act. If the person fails to keep separate books, there shall be levied upon him or her the tax provided for in subsection (1) equal to 6% of the entire gross proceeds of both or all of his or her businesses. The taxes levied by this section are a personal obligation of the taxpayer.

For this purpose, “gross proceeds” is defined as “sales price.” MCL 205.51(1)(c). In turn, “sales price” is defined as “the total amount of consideration, including cash, credit, property, and services, for which tangible personal property or services are sold, leased, or rented, valued in money, whether received in money or otherwise, and applies to the measure subject to sales tax.” MCL 205.51(1)(d). Sales price includes “[c]harges by the seller for any services necessary to complete the sale, other than . . . [l]abor or service charges involved in maintenance and repair work on tangible personal property of others if separately itemized.” MCL 205.51(1)(d)(iii)(B).

Relatedly, pursuant to Mich Admin Code, R 205.117(3), which was in effect during the 2015 through 2018 tax years:

[p]ersons selling tangible personal property in addition to providing labor or service shall obtain a sales tax license and pay the tax on their sales of tangible personal property, including such property sold in connection with repair work. When both labor and service charges are involved in repair work for others, the retailer shall separately itemize the amount charged for the tangible personal property sold; otherwise, the tax shall apply to the total gross proceeds.[1]

Individuals liable for taxes imposed under the GSTA must “keep in a paper, electronic, or digital format an accurate and complete beginning and annual inventory and purchase records of additions to inventory, complete daily sales records, receipts, invoices, bills of lading, and all pertinent documents in a form the department requires.” MCL 205.68(1). Further, under MCL 205.68(4):

(4) If a taxpayer fails to file a return or to maintain or preserve sufficient records as prescribed in this section, or the department has reason to believe that any records maintained or returns filed are inaccurate or incomplete and that additional taxes are due, the department may assess the amount of the tax due from the taxpayer based on an indirect audit procedure or any other information that is available or that may become available to the department. That assessment is

1 Rule 205.117 has since been rescinded, see 2023 Mich Reg 15 (August 11, 2023).

-2- considered prima facie correct for the purpose of this act and the burden of proof of refuting the assessment is upon the taxpayer. An indirect audit of a taxpayer under this subsection must be conducted in accordance with 1941 PA 122, MCL 205.1 to 205.31, and the standards published by the department under section 21 of 1941 PA 122, MCL 205.21, and must include all of the following elements:

(a) A review of the taxpayer’s books and records. The department may use an indirect method to test the accuracy of the taxpayer’s books and records.

(b) Both the credibility of the evidence and the reasonableness of the conclusion must be evaluated before any determination of tax liability is made.

(c) The department may use any method to reconstruct income, deductions, or expenses that is reasonable under the circumstances. The department may use third-party records in the reconstruction. [Emphasis added.]

With respect to an audit by the Department in regard to tax liability, MCL 205.21(1) provides:

If a taxpayer fails or refuses to make a return or payment as required, in whole or in part, or if the department has reason to believe that a return made or payment does not supply sufficient information for an accurate determination of the amount of tax due, the department may obtain information on which to base an assessment of the tax. By its duly authorized agents, the department may examine the books, records, and papers and audit the accounts of a person or any other records pertaining to the tax. A taxpayer who has been audited by the department or its agent or a taxpayer whose books, records, and papers have been examined by the department shall, upon request, be provided a complete copy in printed or electronic format of the complete audit work papers and the audit report of findings. Any audit performed by the department or its duly authorized agents . . . shall be performed in accordance with auditing standards which shall include, but are not limited to, confidentiality, technical training, independence, due professional care, planning, supervision, understanding of the entity audited including internal control and an assessment of risk, audit evidence and documentation, sampling and sampling projections, and elements of the audit report of findings. . . .

“When designing an audit sample, auditors must consider the purpose of the audit procedure and the characteristics of the population from which the sample will be drawn,” and “[t]he auditor may use statistical or nonstatistical sampling.” Mich Admin Code, R 205.2009(1).2 The auditor should

2 Rule 205.2009(6) provides: Auditors may use either statistical or non-statistical sampling of the audited person’s books and records to provide sufficient evidence to form a conclusion about the correct tax liability.

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Bluebook (online)
Sav-Time Inc v. Department of Treasury, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sav-time-inc-v-department-of-treasury-michctapp-2026.