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  5. 845 N.W.2d 81 (2014)
 

FRADCO, INC. v. DEPARTMENT OF TREASURY

Docket Nos. 146333, 146335. Calendar Nos. 4 and 10.

845 N.W.2d 81 (2014)

495 Mich. 104

FRADCO, INC. v. DEPARTMENT OF TREASURY. SMK, LLC, v. Department of Treasury.

Supreme Court of Michigan.

April 1, 2014.

Attorney(s) appearing for the Case

The Novis Law Firm, PLLC, Okemos (by James H. Novis ), for Fradco, Inc., and SMK, LLC.

Bill Schuette , Attorney General, Aaron D. Lindstrom , Solicitor General, and Scott L. Damich , Assistant Attorney General, for the Department of Treasury.

Dykema Gossett PLLC, Grand Rapids (by Wayne D. Roberts and Elisa J. Lintemuth ), for amici curiae the Michigan Association of Certified Public Accountants.

Michele L. Halloran , East Lansing and Christina Thompson for amici curiae the Alvin L. Storrs Low-Income Taxpayer Clinic at Michigan State University College of Law.

YOUNG, C.J.

Michigan's revenue collection act1 provides that, when the Michigan Department of Treasury (the department) issues a final assessment of tax deficiency, a taxpayer has 35 days to appeal that adverse tax decision to the department or 90 days to appeal to the Court of Claims.2 The act also requires that the department provide a copy of a notice of the final assessment to the taxpayer's duly appointed...

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