PER CURIAM.
In these consolidated appeals, Donald Kostyu appeals as of right from an order of the Ingham Circuit Court granting summary disposition under MCR 2.116(C)(4) in favor of the Department of Treasury and the Michigan Tax Tribunal. Kostyu also appeals as of right from an order and judgment of the Tax Tribunal granting a motion to dismiss made by the department. We affirm.
For tax years 1981 and 1982, Kostyu failed or
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