PER CURIAM.
Petitioner appeals as of right from the Michigan Tax Tribunal's April 1, 1982, order granting, sua sponte, summary judgment in favor of the Department of Treasury, affirming the department's denial of petitioner's claim for a single business tax refund.
This case involves interpretation of the Single Business Tax Act (SBTA), MCL 208.1 et seq.; MSA 7.558(1) et seq. The facts are not in dispute. Petitioner is a corporation doing...
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