NEFF, P.J.
This case arose out of a 1986 audit by defendant Michigan Department of Treasury of plaintiff Montgomery Ward & Company, Inc., for the 1982, 1983, and 1984 tax years. On March 3, 1987, a notice of intent to assess a single business tax deficiency was issued by defendant. Plaintiff paid $1,591,811.74 under protest and then appealed the payment to the Court of Claims. Defendant brought a counterclaim which was dismissed for lack of subject-matter jurisdiction...
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