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Vestax Securities Corporation v. Department of Treasury

Citation: Not availableDocket: 142535

Court: Michigan Supreme Court; June 1, 2011; Michigan; State Supreme Court

Original Court Document: View Document

Narrative Opinion Summary

The Michigan Supreme Court, in an order dated June 1, 2011, addressed the appeal filed by Vestax Securities Corporation against the Department of Treasury. The Court reversed the October 28, 2010 judgment of the Court of Appeals, which had determined that independent registered representatives were agents of the plaintiff and that a substantial nexus existed between Michigan and the plaintiff's business activities, justifying the imposition of Michigan's Single Business Tax. The Supreme Court found that the evidentiary record did not support these conclusions. Consequently, the case was remanded to the Court of Claims for reinstatement of an earlier summary disposition order favoring the plaintiff, dated April 27, 2009. Justice Marilyn Kelly expressed a dissenting view, stating she would have granted leave to appeal. The order was certified by Clerk Corbin R. Davis.

Legal Issues Addressed

Dissenting Opinion on Leave to Appeal

Application: Justice Marilyn Kelly dissented, indicating she would have allowed the appeal to proceed.

Reasoning: Justice Marilyn Kelly expressed a dissenting view, stating she would have granted leave to appeal.

Evidentiary Record and Legal Conclusions

Application: The Supreme Court found that the conclusions regarding agency and nexus were not supported by the evidentiary record.

Reasoning: The Supreme Court found that the evidentiary record did not support these conclusions.

Remand for Reinstatement of Summary Disposition

Application: The case was remanded to the Court of Claims to reinstate a previous summary disposition order in favor of the plaintiff.

Reasoning: Consequently, the case was remanded to the Court of Claims for reinstatement of an earlier summary disposition order favoring the plaintiff, dated April 27, 2009.

Reversal of Appellate Court Decision

Application: The Michigan Supreme Court reversed the Court of Appeals decision regarding the status of independent registered representatives and the nexus for tax purposes.

Reasoning: The Court reversed the October 28, 2010 judgment of the Court of Appeals, which had determined that independent registered representatives were agents of the plaintiff and that a substantial nexus existed between Michigan and the plaintiff's business activities, justifying the imposition of Michigan's Single Business Tax.