SAWYER, J.
The sole issue in this case is whether petitioner is eligible for the small business tax credit provided by § 36 of the Single Business Tax Act, MCL 208.1 et seq.; MSA 7.558(1) et seq. Petitioner claimed the credit for tax years 1978 through 1981, inclusive, and respondent disallowed the credit. Petitioner sought review in the Michigan Tax Tribunal, which ruled in favor of respondent. Petitioner now appeals to this Court and we reverse...
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