ET-Petition-NonProp KAT with Order.pdf

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Internal 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

 

_Kuka Assembly & Test Corp 

, 

 

Petitioner(s) 

MICHIGAN TAX TRIBUNAL 

v 

MTT Docket No. 

 

 

_Michigan Department of Treasury 

, 

 

Respondent(s) 

 

ENTIRE TRIBUNAL NON-PROPERTY TAX PETITION 

1. 

Assessment No: MDOT 2025-0934I, ntents to Assess:1474183,1474184,1474185 & 1474188 

 

2. 

The type of tax at issue is 

 

3. 

This appeal involves issues relating to the (check all that are applicable): 

x 

 Tax 

x 

 Interest 

x 

Penalty 

 

 Refund of tax in the amount of $ 

 

4. 

The action that prompted this appeal is 

_A_failure of the audit and collections divisions to coordinate the resolution of an 

audit as agreed to by the parties. 

 

 

5. 

Petitioner’s legal residence or principal office address is: 

6600 Center Drive 

 

Sterling Heights, MI 48312 

 

 

6. 

The amounts as assessed in the Decision and Order of Determination are: 

 

Assessment 

Tax 

Interest 

Penalties 

Payment 

Applied 

Net Due per 

2025-0934 

1474183 

$3,792.89

TBD

$403.00

$0

1474184 

$14,333.64

TBD

$1,433.00

$0

1474185 

$11,584.08

TBD

$1,158.00

$0

1474188 

$11,268.00

TBD

$1,127.00

$8,928.79

 

 

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760 

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906 

Use Tax

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Internal 

MTT Docket No. 

 

Page 2 of 2 

 

7. 

Petitioner contends that the assessment was agreed be as follows and was paid: 

 

Assessment 

Tax 

Interest 

Penalties 

Payment 

Applied 

Net Due per 

agreed audit 

1474183 

 4,031 1,233 

 403 

 5,667 

$0 

1474184 

 14,334 3,777 

 1,433 

 19,544 

$0 

1474185 

 11,584 2,532 

 1,158 

 15,274 

$0 

1474188 

 11,268 1,612 

 1,127 

 14,007 

$0 

Total 

 41,217 

 4,121 

 9,154 

 54,492 

$0 

 

8. 

The tax, interest and penalty in dispute are $8,928.79 or whatever the State currently shows as unpaid: 

 

 

9. 

Petitioner requests the following relief (attach additional page if 

necessary): credit for the costs incurred in this action against future taxes owed 

 

 removal of any open balances due in connection with the assessments: 1474183, 

1474184, 1474185 & 1474188 

 

 

10. 

List the separate and specific facts upon which Petitioner relies to support the 

relief requested (attach additional page if necessary): 

 

a) To effectuate the agreement to the revised amount due shown in paragraph 7 above, 

payment of $54,492.00 was been made online via the collections eservices website on 

September 19, 2025 – Confirmation number 4515641540. 

b) The resolution was in exchange for waiving a scheduled informal conference. 

c) Collections did not provide adequate detail in the Order. 

d) The 60th day after the Order was March 21st which fell on a Saturday, the first business day 

thereafter was Monday March 23, 2026. 

Signature of Petitioner’s Authorized Representative or, if none, Petitioner: 

Printed Name of Petitioner’s Authorized Representative or, if none, Petitioner: 

 

 

Christopher P. Wylie 

 

Email Address: chris.wylie@kuka.com 

 

 

Mailing Address: 

Attn Tax Department, 6600 Center Drive, Sterling Heights, MI 48312 

 

Telephone Number: 248-207-5555 

 

 

Date: May 23, 2026

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STATE OF MICHIGAN 

DEPARTMENT OF TREASURY 

DECISION AND ORDER OF DETERMINATION 

Kuka Assembly & Test Corp 

Christopher Wylie 

6600 Center Drive 

Sterling Heights, Ml 48312 

Docket No. 2025-0934 

Use Tax 

Intents to Assess: 

1474183,1474184,1474185 

1474188 

Tax Periods: 12/2020-12/2023 

Audit Period: 8/2020-12/2023 

The Department, having reviewed the evidence and recommendation of the Referee in the 

above captioned matter, and being advised in the premises; and 

It appearing that this recommendation is supported by authority and reasoned opinion, and 

that the same accordingly be accepted; 

It is ordered and determined that the determined tax due listed on workpapers dated February 

27, 2025 is upheld. 

It further ordered and determined that Intent to Assess 1474183 is upheld as adjusted for tax in 

the amount of $3,792.89, penalty in the amount of $403.00 plus interest to be determined in 

accordance with 1941 PA 122, as amended. After application of payment the Intent to Assess 

1474183 is paid in full. 

It is further ordered and determined that Intent to Assess 1474184 is upheld as adjusted for tax 

in the amount of $14,333.64, penalty in the amount of $1,433.00 plus interest to be 

determined in accordance with 1941 PA 122, as amended. After application of payment, Intent 

to Assess 1474184 is paid in full. 

It is ordered and determined that Intent to Assess 1474185 is upheld as adjusted for tax in the 

amount of $11,584.08, penalty in the amount of $1,158.00 plus interest to be determined in 

accordance with 1941 PA 122, as amended. After application of payment, Intent to Assess 

1474185 is paid in full. 

It is ordered and determined that Intent to Assess 1474188 is upheld as adjusted for tax in the 

amount of $11,268.00, penalty in the amount of $1,127.00 and interest to be determined in 

accordance with 1941 PA 122, as amended. After application of payment, the balance due is 

$8,928.79 plus interest to be determined in accordance with 1941 PA li2. 

00118904000002040200

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Docket No. 2025-0934 

Page 20f 2 

It is further ordered and determined that the Department shall issue a final assessment against 

you for the remaining tax and interest due on Intent to Assess 1474188. The tax due on this 

assessment will be subject to the accrual of such additional interest as is provided by 1941 PA 

122, as amended. The final assessment will include a statement advising you of your appeal 

rights with respect to that bill. 

If you disagree with all or part of this Decision and Order of Determination you may, as 

provided at MCL 205.22, appeal to the Michigan Tax Tribunal within 60 days of this Decision 

and Order of Determination, or to the Michigan Court of Claims at any of its District Offices, 

within 90 days of this Decision and Order of Determination. All undisputed amounts must be 

paid prior to appeal. Appeal instructions and contact information for the Michigan Tax Tribunal 

are available at www.mi.gov/taxtrib. Appeal instructions and contact information for the Court 

of Claims District Offices are available at www.courts.michigan.gov/courts/court-of-claims. 

Sor 

A fol 

RegindR. Blough, Admifiistrator 

Hearings Division 

On Behalf of the State Treasurer 

DATED: 

JAN 20, 2026 

CERTIFIED MAIL - RETURN RECEIPT REQUESTED

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5753 (07-21) 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF TREASURY 

RACHAEL EUBANKS 

GOVERNOR 

LANSING 

STATE TREASURER 

Dear Informal Conference Participant, 

RE: Hearings Division — Satisfaction Survey 

This letter is being sent to you because you recently participated in some aspect of the informal 

conference process with the Hearings Division of the Michigan Department of Treasury. 

The Hearings Division has been actively working toward improving the informal conference 

process. Our focus has been on improving communication and working toward operational 

efficiencies within our work area to reduce the number of days that it takes to process files, hold 

conferences and issue Decision and Orders. 

In an effort to gauge how well we are managing change while maintaining quality customer 

service, we invite you to participate in a customer satisfaction survey. 

To participate in the survey, please type the following URL link in your browser field: 

https://forms.office.com/g/0iX4CrSvRP 

Or scan the following QR code with your mobile device: 

We appreciate your honest opinion and look forward to your responses as we continue to set 

future goals to further improve our processes. 

Respectfully,

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USPS CERTIFIED MAIL™ 

PITNEY BOWES 

$8.869 

US POSTAGEM 

+ 

FIRST-CLASS 

3003845462 

21P 48813 

9414 8149 0398 3949 0087 08 

Kuka Assembly 

& 

Test Corp 

Christopher Wylie 

6600 Center Drive 

Sterling Heights, 

MI 

48312

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STATE OF MICHIGAN 

DEPARTMENT OF TREASURY 

Kuka Assembly & Test Corp 

Docket No. 2025-0934 

Christopher Wylie 

Use Tax 

6600 Center Drive 

Intents to Assess: 

Sterling Heights, Mi 48312 

1474183, 1474184, 1474185 

1474188 

Tax Periods: 12/2020-12/2023 

Audit Period: 8/2020-12/2023 

INFORMAL CONFERENCE RECOMMENDATION 

The above matter was scheduled for November 4, 2025. 

Prior to conference, Kuka Assembly & 

Test Corp (petitioner) withdrew its appeal in a letter dated September 19, 2025, stating in part: 

In recognition of the revisions made in the total amount due as represented in the 

Revised Audit Package, in particular, the tax due and penalty and interest on 

Schedule A-1 [workpapers dated February 27, 2025]. 

. 

. we are in agreement that 

there no longer remains a material difference in opinion necessitating an informal 

conference or any other further appeal. 

* Xk 

To effectuate the agreement to the revised amount due, payment of $54,492.00 has 

been made online via the collections eservices website on September 19, 2025- 

Confirmation number 4515641540. 

* kk 

Therefore we are writing to withdraw our request for an informal conference. 

Based on the above, 

a decision and order should be issued reflecting the Department's revised 

determination. 

RECOMMENDATION 

It is recommended the workpapers dated February 2, 2025, should be upheld as adjusted and the

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