Full record / 25-003857 Green Bronco LLC Answer .pdf

25-003857 Green Bronco LLC Answer .pdf

Green Bronco LLC, Petitioner Vs. Michigan Department Of Treasury, Respondent · 25-003857-TT

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RESPONSE TO PETITIONER’S REASON FOR APPEAL 

MTT Docket No. 25-003857 

SALES TAX 

GREEN BRONCO LLC, PETITIONER 

Filing 

The Tax Policy Division, Department of Treasury, prepares this answer in response to a 

petition filed with the Small Claims Division of the Michigan Tax Tribunal by Green Bronco 

LLC. (“Petitioner”). A copy of this answer has been served concurrently on the Petitioner. 

Petition 

Petitioner is appealing the outcome of a sales tax audit that took place alongside a 

marihuana retailers excise tax (MRE) audit, resulting in assessments issued for both 

taxes for the 2022 and 2023 tax years. The petition relates to the sales tax 

assessments only. 

Background 

On or around April 2025, Treasury conducted an audit of Petitioner’s sales tax and 

marihuana retailers excise tax (MRE) returns for the period of March 2021 through 

December 2024. Upon the completion of the audit, Treasury issued multiple intents to 

assess for the MRE tax (assessment numbers 1714100 and 1714101) as well as multiple 

intents to assess for sales tax (assessment numbers 1702103 and 1702106). Petitioner 

timely appealed the MRE assessments and an informal conference was scheduled for 

November 7, 2025. Unfortunately, Petitioner’s request to appeal the sales tax 

assessments was not timely received and was subsequently denied in accordance with 

MCL 205.21(2)(c). Prior to the conference relating to the MRE assessments, Petitioner 

supplied accurate data to replace previously reported incorrect data. 

The Department’s auditors reviewed the new data and made adjustments to its audit 

determination related to the MRE assessments, resulting in the issuance of new Audit 

Workpapers on November 6, 2025, which were then shared with Petitioner. On November 

12, 2025, Petitioner notified the Department by letter that based on the adjustments 

made, the matter had been resolved and that it no longer wished to continue with the 

informal conference. The Hearings Referee recommended that the request to withdraw 

the informal conference be granted in compliance with section 21 of the Revenue Act. 

The Department has not yet issued a decision adopting the Recommendation. 

Petitioner’s Claims 

Petitioner claims that the State relied on incorrect data to issue assessments for both the 

sales tax and MRE tax subsequent to the completion of an audit. Petitioner did not timely 

appeal the sales tax assessments at issue in this petition. However, it did timely request 

informal conference on the MRE tax assessments and supplied corrected data in 

connection with that request. The data was accepted as to the MRE tax assessments 

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and adjustments made, though no formal decision has yet been issued reflecting a 

modification of the MRE assessments. 

Petitioner requests that the same data correction be applied to the Department’s sales 

tax assessments because the underlying data used to determine the outcome of the MRE 

assessments is the same data used to determine the outcome of the sales tax 

assessments. Petitioner asserts that if the data was accepted for the MRE liability 

determination, it should also be accepted for the sale tax liability determination. 

Respondent’s Answer 

The Department agrees that the same data should be used to formulate the tax liability 

for both sales tax and the MRE tax. The Department’s audit division is in the process of 

recalculating the sales tax liability in accordance with the corrected data supplied. 

Adjustments to the assessments are likely but those have not yet been recalculated. 

Relief 

Until such time that Treasury’s Audit Division can review the new information and make 

a final determination, Respondent requests that the Court uphold the assessments as 

issued. 

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