Michigan Compiled Laws
Mich. Comp. Laws § 206.20 (2026)
Sales and state; definitions.
✓ current as of July 2026
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INCOME TAX ACT OF 1967
Act 281 of 1967
206.20 Sales and state; definitions.
Sec. 20.
(1) "Sales" means all gross receipts of the taxpayer not allocated under sections 110 to 114.
(2) "State" means any state of the United States, the District of Columbia, the Commonwealth of Puerto Rico, any territory or possession of the United States, and any foreign country, or political subdivision, thereof.
History: 1967, Act 281, Eff. Oct. 1, 1967 ;-- Am. 1969, Act 332, Imd. Eff. Nov. 4, 1969
Notes of Decisions
Cited in 5
cases, 1977–2013 · 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). “[ 38 ] Finally, MCL 206.20 defines “state” as “any state of the United States, the District of Columbia, the Commonwealth of Puerto Rico, any territory or possession of the United States, and any foreign country, or political *253 subdivision, thereof.”
Ludka v. Dep't of Treasury, 399 N.W.2d 490 (Mich. Ct. App. 1986). “[MCL 206.20; MSA 7.557(120).] *256 Plaintiffs argue that the deletion of these modifying words evidences a legislative intent that "state” was to be given its generic meaning as provided in §20(2).”
Shulevitz v. Dep't of Treasury, 261 N.W.2d 31 (Mich. Ct. App. 1977). “However, plaintiffs direct us to the general definition section of the act, and more specifically to *658 MCLA 206.20; MSA 7.557(120), which reads in part: " 'State’ means any state of the United States, the District of Columbia, the Commonwealth of Puerto Rico, any territory or…”
Wheeler Est. v. Dep't of Treasury, 825 N.W.2d 588 (Mich. Ct. App. 2012). “20 as “any state of the United States, the District of Columbia, the Com *421 monwealth of Puerto Rico, any territory or possession of the United States, and any foreign country, or political subdivision, thereof.” (Emphasis added.) As such, any taxpayer having income from a…”
Est. of Thomas M Wheeler v. Dep't of Treasury (Mich. 2013). “105, and MCL 206.20 require unitary businesses that include foreign entities to allocate and apportion their income as provided by the ITA.”
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