Wis. Mich. S.S. Co. v. C. S. Comm

3 Citing cases

  1. International Telephone & Telegraph Corp. v. Michigan

    50 Mich. App. 5 (Mich. Ct. App. 1973)   Cited 2 times

    Judge Corkin has ably analyzed and extensively quoted from this case so that it requires no further comment here. In Wisconsin Michigan Steamship Co v Corporation Securities Commission, 371 Mich. 61; 123 N.W.2d 258 (1963), Justice SOURIS pointed out that Duluth, S S A R Co v Corporation Securities Commission, 353 Mich. 636; 92 N.W.2d 22 (1958), severely limited the earlier and more restrictive decisions in Gartland Steamship Co v Corporation Securities Commission, 339 Mich. 661; 64 N.W.2d 886 (1954), and Panhandle Eastern Pipe Line Co v Corporation Securities Commission, 346 Mich. 50; 77 N.W.2d 249 (1956). Justice SOURIS wrote (pp 71-72, 73; 123 N.W.2d pp 263, 264):

  2. United Air Lines v. Dept. of Treasury

    29 Mich. App. 242 (Mich. Ct. App. 1970)   Cited 2 times

    This apportionment is determined by the formula specified in MCLA § 450.305 (Stat Ann 1970 Cum Supp § 21.208). The statutory fee requirement and method of determination were approved in Wisconsin Michigan Steamship Company v. Corporation Securities Commission (1963), 371 Mich. 61. In its brief, plaintiff concedes, "a state * * * within reasonable limits may compute the amount of the charge [for doing an intrastate business] by applying the tax rate to a fair proportion of the taxpayer's business done within the state, including both interstate and intrastate."

  3. Aluminum Co. of A. v. Dept. of Treas. of Mich.

    384 F. Supp. 1143 (E.D. Mich. 1974)   Cited 1 times

    Certainly, an interpretation of the Act which sanctions the imposition of a tax upon corporations, "engaging in any transaction" in the state would be unconstitutional if applied to wholly interstate transactions. Wisconsin Michigan Steamship Co. v. Corporation Securities Commission, 371 Mich. 61, 67, 123 N.W.2d 258 (1963). Furthermore, the defendant Franchise Fee Division premised its assessment against Alcoa upon a finding that Alcoa was "doing business" or was "privileged to do business" in Michigan.