Mich. Comp. Laws » Michigan Compiled Laws / Chapter 206 / Act 281 of 1967
Michigan Compiled Laws

Mich. Comp. Laws § 206.121 (2026)

Sales factor; determination.

✓ current as of July 2026
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INCOME TAX ACT OF 1967


Act 281 of 1967


206.121 Sales factor; determination.

Sec. 121.

    The sales factor is a fraction, the numerator of which is the total sales of the taxpayer in this state during the tax period, and the denominator of which is the total sales of the taxpayer everywhere during the tax period.

History: 1967, Act 281, Eff. Oct. 1, 1967

Notes of Decisions
Cited in 8 cases, 1981–2013 · leading case: Tad Malpass v. Dep't of Treasury, 833 N.W.2d 272 (Mich. 2013).
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Tad Malpass v. Dep't of Treasury, 833 N.W.2d 272 (Mich. 2013). “” 43 Likewise, MCL 206.121 states that “[t]he sales factor is a fraction,.”
Grunewald v. Dep't of Treasury Wortley, 305 N.W.2d 269 (Mich. Ct. App. 1981). “557(1119), MCL 206.121; MSA 7.557(1121). Each factor in the present case is zero; thus, the fraction specified by § 115 is 0/3, and none of the taxpayers’ income from the limited partnership is attributable to Michigan.”
Malpass v. Dep't of Treasury, 295 Mich. App. 263 (Mich. Ct. App. 2011). “119, and MCL 206.121. For an individual or business to apply the unitary-business principle, there must “be some sharing or exchange of value not capable of precise identification or measurement — beyond the mere flow of funds arising out of a passive investment or a distinct…”
Wheeler Est. v. Dep't of Treasury, 825 N.W.2d 588 (Mich. Ct. App. 2012). “” MCL 206.121. The Legislature’s use of the words “all” and “everywhere” in these definitions makes it clear that there is no specific prohibition on apportioning business income through the addition of international apportionment factors, provided that the international…”
Preston v. Dep't of Treasury, 815 N.W.2d 781 (Mich. Ct. App. 2011). “119, and MCL 206.121. In order to apply Michigan’s apportionment formula there must “ ‘be some sharing or exchange of value not capable of precise identification or measurement— beyond the mere flow of funds arising out of a passive investment or a distinct business operation —…”
Wilson v. Dep't of Treasury, 333 N.W.2d 3 (Mich. Ct. App. 1982). “557(1119), MCL 206.121; MSA 7.557(1121). Each factor in the present case is zero; thus, the fraction specified by § 115 is 0/3, and none of the taxpayers’ income from the limited partnership is attributable to Michigan.”
Est. of Thomas M Wheeler v. Dep't of Treasury (Mich. 2013). “”43 Likewise, MCL 206.121 states that “[t]he sales factor is a fraction, .”
Winget v. Dep't of Treasury, 847 N.W.2d 653 (Mich. Ct. App. 2013). “119, and MCL 206.121. Petitioners argue that apportionment of business income under MCL 206.”
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