Michigan Compiled Laws
Mich. Comp. Laws § 206.103 (2026)
Taxable income partly attributable to state.
✓ current as of July 2026
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INCOME TAX ACT OF 1967
Act 281 of 1967
206.103 Taxable income partly attributable to state.
Sec. 103.
Any taxpayer having income from business activity which is taxable both within and without this state, other than the rendering of purely personal services by an individual, shall allocate and apportion his net income as provided in this part.
History: 1967, Act 281, Eff. Oct. 1, 1967 ;-- Am. 1970, Act 140, Imd. Eff. Aug. 1, 1970 ;-- Am. 2011, Act 38, Eff. Jan. 1, 2012
Notes of Decisions
Cited in 14
cases, 1981–2013 · leading case: Tad Malpass v. Dep't of Treasury, 833 N.W.2d 272 (Mich. 2013).
Tad Malpass v. Dep't of Treasury, 833 N.W.2d 272 (Mich. 2013). “23 MCL 206.103. 24 MCL 206.110(1). 25 Emphasis added.”
Donovan Constr. Co. v. Dep't of Treasury, 337 N.W.2d 297 (Mich. Ct. App. 1983). “MCL 206.103; MSA 7.557(1103). This is a version of the Uniform Division of Income for Tax Purposes Act.”
Wisne v. Dep't of Treasury, 625 N.W.2d 401 (Mich. Ct. App. 2001). “[MCL 206.103; MSA 7.557(1103).] Sec. 110. (1) For a resident individual, estate, or trust, all taxable income from any source whatsoever, except that attributable to another state under sections 111 to 115 and subject to section 255, is allocated to this state.”
Wheeler Est. v. Dep't of Treasury, 825 N.W.2d 588 (Mich. Ct. App. 2012). “Under the ITA, if a taxpayer’s income-producing activities are confined solely to Michigan, then the taxpayer’s entire income must be allocated to Michigan. MCL 206.102.”
Chocola v. Dep't of Treasury, 369 N.W.2d 843 (Mich. 1985). “[MCL 206.103; MSA 7.557(1103).] Sec. 105. For purposes of allocation and apportionment of income from business activity under this act, a taxpayer is taxable in another state if (a) in that state he is subject to a net income tax, a franchise tax measured by net income, a…”
Grunewald v. Dep't of Treasury Wortley, 305 N.W.2d 269 (Mich. Ct. App. 1981). “” MCL 206.103; MSA 7.557(1103). The limited partnership income in the present case falls under the category of income from business activity taxable both within and without this state.”
Bachman v. Dep't of Treasury, 544 N.W.2d 733 (Mich. Ct. App. 1996). “[MCL 206.103; MSA 7.557(1103).] Sec. 110. (1) In the case of a resident individual, estate or trust all taxable income from any source whatsoever, except that attributable to another state under the provisions of sections 111 to 115 and subject to the credit provisions of…”
Preston v. Dep't of Treasury, 815 N.W.2d 781 (Mich. Ct. App. 2011). “MCL 206.103. Income is apportioned to Michigan “by multiplying the income by a fraction, the numerator of which is the property factor plus the payroll factor plus the sales factor, and the denominator of which is 3.”
Chocola v. Dep't of Treasury, 348 N.W.2d 290 (Mich. Ct. App. 1984). “MCL 206.103; MSA 7.557(1103). The chapter provides that in the case of resident individuals, such as petitioners in the instant case, all taxable income from any source whatsoever is allocable to Michigan with the exception of that income attributable to another state under the…”
Detroit Bank & Trust Co. v. Dep't of Treasury, 377 N.W.2d 425 (Mich. Ct. App. 1985). “The Tax Tribunal found that petitioner properly utilized MCL 206.103 and 206.105; MSA 7.557(1103) and 7.”
Wilson v. Dep't of Treasury, 333 N.W.2d 3 (Mich. Ct. App. 1982). “” MCL 206.103; MSA 7.557(1103). "For purposes of allocation and apportionment of income from business activity under this act, a taxpayer is taxable in another state if (a) in that state he is subject to a net income tax, a franchise tax measured by net income, a franchise tax…”
Payne & Dolan of Wisconsin, Inc v. Dep't of Treasury, 360 N.W.2d 208 (Mich. Ct. App. 1984). “” MCL 206.103; MSA 7.577(1103). The act sets forth the following apportionment formula, which was utilized by petitioner in filing its Michigan tax return: • "All business income, other than income from transportation services, domestic insurers and financial organizations,…”
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