Honigman Miller Schwartz and Cohn LLP v. City of Detroit, 952 N.W.2d 358

Honigman Miller Schwartz & Cohn LLP (law firm) operated in Detroit and elsewhere and apportioned taxable net profit under the Uniform City Income Tax Ordinance (UCITO), MCL 141.601 et seq.
Dispute concerned the revenue factor (MCL 141.623): whether “gross revenue … derived from … services rendered in the city” includes legal services performed in Detroit for clients located outside the city or only services delivered to in-city clients.
Tax Tribunal granted summary disposition to the City of Detroit, concluding “services rendered in the city” refers to where services are performed (origin test).
Michigan Court of Appeals reversed, holding “rendered” meant “delivered” (market/destination test) and thus only revenues for services delivered to clients in Detroit count as in-city.
Michigan Supreme Court granted leave, reversed the Court of Appeals, held “rendered” means “to do (a service) for another,” adopted an origin test for services under MCL 141.623, and remanded to the Tribunal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Meaning of “services rendered in the city” in MCL 141.623	Honigman: “rendered” = delivered/transmitted to client (market/destination sourcing); count only revenues for services delivered to in-city clients	City: “rendered” = done/carried out in the city (origin sourcing); count revenues for services performed in-city regardless of client location	Court held “rendered” means to do a service for another; revenue factor uses an origin test (source = where service is performed)
Significance of differing words “performed” (MCL 141.622) vs “rendered” (MCL 141.623)	Honigman/Ct. of Appeals: different words imply different meanings; “performed” = done; “rendered” = delivered	City/Tribunal: terms are contextually synonymous here and both focus on where work is done; different wording reflects context, not a market-based shift	Court held terms have similar plain meanings but different connotations in context; consistent-usage canon does not control outcome—both provisions look to where services are done

Mich Props, LLC v. Meridian Twp, 491 Mich 518 (2012) (de novo review of Tax Tribunal legal questions)
El-Khalil v. Oakwood Healthcare, Inc., 504 Mich 152 (2019) (standard for summary disposition under MCR 2.116(C)(10))
Danse Corp v. Madison Hts, 466 Mich 175 (2002) (statutory interpretation principles)
Sweatt v. Dep’t of Corrections, 468 Mich 172 (2003) (read statutory words in light of whole act and context)
In re Rovas Complaint Against SBC Mich, 482 Mich 90 (2008) (administrative interpretation entitled to respectful consideration)
IBM Corp v. Dep’t of Treasury, 496 Mich 642 (2014) (history of apportionment rules and origin vs market sourcing for services)
Honigman Miller Schwartz & Cohn LLP v. Detroit, 322 Mich App 667 (2018) (Court of Appeals decision reversing Tribunal on "rendered" = delivered)
Oakland Co Bd of Co Rd Comm’rs v. Mich Prop & Cas Guaranty Ass’n, 456 Mich 590 (1998) (use of dictionary definitions for undefined statutory terms)