Petitioner contends Respondent incorrectly aggregated the gross receipts and officer compensation of Petitioner and the Credit Union. Petitioner further contends Respondent erred in using the gross receipts method instead of the business income method to calculate the 1990 SBT liability. Therefore, the issue of the proper method is moot. In fact, the Credit Union is not required to file a SBT return. When there is doubt, tax statutes are to be construed most strongly against the government.
Petitioner states it is a Michigan corporation.
Petitioner avows the Credit Union has no unrelated business taxable income. Petitioner cites Saginaw General Health Enterprises, Inc v Michigan Department of Treasury - Bureau of Revenue , No. Petitioner opines Respondent cannot usurp the exempt status of Federal Credit Unions under 12 USC 1768. Respondent further contends the rules of statutory construction require consolidation of Petitioner's activities with its non-profit parent. The issue here is a credit, relief from a fixed tax obligation, and the principle rule in statutory construction is that ambiguities shall be resolved in favor of the taxing authority.