Ford Motor Company v. Department of Treasury, 496 Mich. 382

Ford paid disputed Single Business Tax amounts (VEBA contributions) by applying funds on deposit to assessed liabilities no later than Oct 31, 2002.
Treasury audited, issued an Aug 3, 2005 Audit Determination Letter assessing additional tax and interest; Ford checked “disagree” and returned the letter.
Ford requested an informal conference (Nov 17, 2005), later withdrew that request and on Aug 25, 2006 mailed a letter stating it would file in Court of Claims and that its payment should be viewed as a payment under protest (citing MCL 205.22).
Ford filed a Court of Claims complaint on Dec 13, 2006; the Court of Appeals ultimately held Ford was entitled to a refund.
Parties disputed the date that triggered accrual of interest under MCL 205.30(3) (45 days after a claim is filed): Ford argued Sept 17, 2005 (45 days after Aug 3 response); Treasury argued 45 days after Dec 13, 2006 (complaint filing).
Trial court ruled for Ford (interest from Oct 9, 2006 based on Aug 25, 2006 letter); Court of Appeals reversed on interest timing; Michigan Supreme Court granted leave and addressed statutory interpretation of MCL 205.30.

Issue	Plaintiff's Argument	Defendant's Argument	Held
What actions trigger interest accrual under MCL 205.30(3)?	Ford: interest starts 45 days after taxpayer gives Treasury adequate notice of a claim (Ford argued earlier notice sufficed).	Treasury: interest starts 45 days after an actual filed claim/complaint (i.e., complaint on Dec 13, 2006).	Court: statute requires (1) payment of disputed tax, (2) a “claim” or “petition” that clearly demands/request a refund, and (3) that the claim be “filed” — i.e., submitted to Treasury so it has adequate notice; interest runs 45 days after that filing.
Whether Ford’s communications constituted a filed claim that triggered interest (Aug 3, 2005 response; Nov 17, 2005 informal conference request; Aug 25, 2006 letter; Dec 13, 2006 complaint)	Ford: Aug 3 response (and audit-related communications) gave Treasury adequate notice; Aug 25 letter served as a claim filed and thus triggered interest 45 days later.	Treasury: no clear demand for refund until Ford’s complaint; earlier communications merely expressed disagreement or sought conference and did not constitute a filed claim.	Court: Aug 3 and Nov 17 communications did not constitute a claim; Aug 25, 2006 letter (with withdrawal of informal conference, notice of suit, and citation to MCL 205.22) did assert a right to refund and was received by Treasury — it therefore was a filed claim and triggered interest beginning Oct 9, 2006 (45 days later).

NSK Corp. v. Dep’t of Treasury, 481 Mich 884 (2008) (a claim must be made by the taxpayer in a return or separate request; Treasury’s mere awareness of entitlement doesn’t trigger interest)
Sun Valley Foods Co. v. Ward, 460 Mich 230 (1999) (statutory interpretation begins with text and enforces unambiguous language)
Malpass v. Dep’t of Treasury, 494 Mich 237 (2013) (statutory interpretation reviewed de novo)
Klooster v. City of Charlevoix, 488 Mich 289 (2010) (use of dictionaries to determine ordinary meaning when statute lacks definition)
Muldavin v. Dep’t of Treasury, 184 Mich App 222 (1990) (tax overpayment must be requested on return or by separate petition)
Lindsay Anderson Sagar Trust v. Dep’t of Treasury, 204 Mich App 128 (1994) (letter requesting refund constituted a claim when it clearly demanded refund)
Detroit v. Ambassador Bridge Co., 481 Mich 29 (2008) (clear-error standard for factual findings)