William S Jenks v. Department of Treasury, 332787

William S. Jenks was assessed personally under MCL 205.27a for unpaid withholding taxes of Jenks Plumbing and Heating Inc.; liens issued for over $70,000.
Statutory appeal windows existed: 35 days to the Michigan Tax Tribunal (then), 90 days to the Court of Claims under MCL 205.22. Jenks did not file within those windows.
Jenks paid divisible portions of 16 withholding assessments and filed a refund claim under MCL 205.30 asserting the taxes were “unjustly assessed.”
The Department of Treasury denied the refund, treating the claim as a collateral attack on final assessments barred by MCL 205.22(4)–(5).
Jenks appealed to the Michigan Tax Tribunal; the Tribunal granted summary disposition for the Department under MCR 2.116(C)(4), (7), and (10).

Issue	Jenks’s Argument	Department’s Argument	Held
Whether a refund claim under MCL 205.30 may be used to challenge a final assessment after MCL 205.22 appeal deadlines have passed	Jenks: Paying a divisible portion and filing a refund claim allows him to contest that the assessment was "unjustly assessed" despite missed appeal deadlines	Dept: MCL 205.22(4)–(5) makes unappealed assessments final and bars collateral attacks, so a refund claim that attacks a final assessment is barred	Court: Affirmed—refund claim that collaterally attacks a conclusive assessment is barred by MCL 205.22(4)–(5)

Meijer, Inc v. City of Midland, 240 Mich. App. 1 (appellate review limited to legal error; factual findings upheld if supported by substantial evidence)
Peters v. Department of Corrections, 215 Mich. App. 485 (de novo review of summary disposition)
PIC Maint, Inc. v. Dep’t of Treasury, 293 Mich. App. 403 (statutory interpretation reviewed de novo)
People v. Peltola, 489 Mich. 174 (Legislature’s plain statutory language controls)
Ross v. Modern Mirror & Glass Co., 268 Mich. App. 558 (court must enforce plain meaning of statute)