Michigan Court of Appeals September 6, 1988, Docket 99464 (J C Penney Co. v. Department of Treasury)

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R. L. Tahvonen, J.

The J.C. Penney Company appeals as of right from a judgment of the Michigan Tax Tribunal upholding the Treasury Department’s determination that certain sums had been improperly deducted in the calculation of Penney’s single business tax for tax years ending in January of 1978, 1979, 1980, and 1981.