Michigan Court of Appeals April 19, 2012, Docket Nos. 303736 and 303737 (Kelly Services, Inc. v. Department of Treasury)

Per Curiam.

Respondent, the Department of Treasury, appeals as of right an order of the Tax Tribunal that granted summary disposition in favor of petitioners, Kelly Services, Inc., and Kelly Properties, Inc., and denied respondent summary disposition. We affirm.

I. BASIC FACTS AND PROCEDURAL HISTORY

Petitioners are an affiliated group of companies.