No. 23-443
MMN Infrastructure Services, LLC, Successor in Interest to Vectren Infrastructure Services Corp. v. Michigan Department of Treasury
Tags: corporate-disclosure extraterritorial-taxation factor-representation fair-apportionment interstate-commerce short-tax-year tax-apportionment tax-assessment temporal-element
Key Terms:
AdministrativeLaw DueProcess JusticiabilityDoctri
AdministrativeLaw DueProcess JusticiabilityDoctri
Latest Conference:
2023-11-17
Question Presented (from Petition)
1. Whether, to comply with the requirements of fair apportionment and the prohibition on extraterritorial taxation, a state must include in its state tax apportionment formula the factors of a business giving rise to income to be taxed.
2. Whether factor representation includes a temporal element.
Question Presented (AI Summary)
Whether a state must include in its tax apportionment formula the factors of a business giving rise to income to be taxed, and whether factor representation includes a temporal element
Docket Entries
2023-11-20
Petition DENIED.
2023-11-15
Brief amicus curiae of Council On State Taxation filed. (Distributed)
2023-11-14
Brief amicus curiae of American College of Tax Counsel filed. (Distributed)
2023-11-10
Brief amicus curiae of The Institute for Professionals in Taxation filed. (Distributed)
2023-11-01
DISTRIBUTED for Conference of 11/17/2023.
2023-10-31
Waiver of right of respondent Michigan Department of Treasury to respond filed.
2023-10-25
Petition for a writ of certiorari filed. (Response due November 27, 2023)
Attorneys
American College of Tax Counsel
Dirk Giseburt — Davis Wright Tremaine LLP, Amicus
Council On State Taxation
Karl A. Frieden — Council On State Taxation, Amicus
Michigan Department of Treasury
Ann Maurine Sherman — Michigan Department of Attorney General, Respondent
MMN Infrastructure Services, LLC
John J. Bursch — Bursch Law PLLC, Petitioner
The Institute for Professionals in Taxation