Kuka Assembly & Test Corp Petitioner Vs. Michigan Department Of Treasury Respondent

Page 1

STATE OF MICHIGAN 

 

GRETCHEN WHITMER 

GOVERNOR 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

LANSING 

MARLON I. BROWN, DPA 

DIRECTOR 

 

 

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 

Kuka Assembly & Test Corp, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

SMALL CLAIMS DIVISION 

 

v 

 

MTT Docket No. 26-000368 

 

Michigan Department of Treasury, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER GRANTING JUDGMENT IN FAVOR OF PETITIONER UNDER 

MCR 2.116(I)(1) 

 

FINAL OPINION AND JUDGMENT 

 

The Tribunal has reviewed the file in this case and finds that Petitioner filed this appeal 

on March 23, 2026, disputing the Decision and Order of Determination issued relative to 

Final Assessment Nos. 1474183, 1474184, 1474185, and 1474188, which was issued 

by Respondent on January 20, 2026. On June 8, 2026, Respondent filed an answer 

stating that Petitioner reached an agreement with the Audit Division regarding the 

amount of the determined liability and submitted payment as agreed. The settlement 

amount was not processed correctly by the Collections Division and the assessments 

were not properly reduced to match the amounts of the settlement agreement. The 

Revenue Services Division made corrections to the assessments to agree with the 

reduced amount of the settlement, and upon the corrections being processed, the 

Collections Division canceled the assessments. Several attempts have been made to 

contact Petitioner to advise them that the assessments have been cancelled but no 

response has been received. 

 

MCR 2.116(I)(1) states that “if the pleadings show that a party is entitled to judgment as 

a matter of law, or if the affidavits or other proofs show that there is no genuine issue of 

material fact, the court shall render judgment without delay.” Given that Respondent 

has indicated that the assessments have been cancelled, and that it has granted 

Petitioner the full extent of the relief requested in the petition, the Tribunal finds that 

judgment in favor of Petitioner is appropriate.1 Therefore, 

 

IT IS ORDERED that judgment is GRANTED in favor of Petitioner. 

 

IT IS FURTHER ORDERED that Final Assessment Nos. 1474183, 1474184, 1474185, 

and 1474188 are CANCELLED. 

 

1 Though Respondent requested dismissal of the case, this request is not properly pending because 

Respondent failed to file a motion accompanied by the appropriate fee, as required by TTR 231. 

Dismissal is also not warranted, as Respondent failed to file any documentation establishing that the 

requested relief has in fact been granted.

Page 2

MTT Docket No. 26-000368 

Page 2 of 2 

 

IT IS FURTHER ORDERED that Respondent shall cause its records to be corrected to 

reflect the taxes, interest, and penalties within 20 days of entry of this Final Opinion and 

Judgment. 

 

IT IS FURTHER ORDERED that Respondent shall collect the affected taxes, interest, 

and penalties or issue a refund as required by this opinion within 28 days of entry of this 

Final Opinion and Judgment. 

 

This opinion resolves the last pending claim and closes the case. 

 

APPEAL RIGHTS 

If you disagree with the final decision in this case, you may file a motion for 

reconsideration with the Tribunal or a claim of appeal with the Michigan Court of 

Appeals. 

 

A motion for reconsideration must be filed with the Tribunal with the required filing fee 

within 21 days from the date of entry of the final decision. Because the final decision 

closes the case, the motion cannot be filed through the Tribunal’s web-based e-filing 

system; it must be filed by mail or personal service. The fee for the filing of such 

motions is $50.00 in the Entire Tribunal and $25.00 in the Small Claims Division, unless 

the Small Claims decision relates to the valuation of property and the property had a 

principal residence exemption of at least 50% at the time the petition was filed or the 

decision relates to the grant or denial of a poverty or disabled veterans exemption and, 

if so, there is no filing fee. You are required to serve a copy of the motion on the 

opposing party by mail or personal service or by email if the opposing party agrees to 

electronic service, and proof demonstrating that service must be submitted with the 

motion. Responses to motions for reconsideration are prohibited and there are no oral 

arguments unless otherwise ordered by the Tribunal. 

 

Alternatively, you may file a claim of appeal with the Michigan Court of Appeals. If the 

claim is filed within 21 days of the entry of the final decision, it is an “appeal of right.” If 

the claim is filed more than 21 days after the entry of the final decision, it is an “appeal 

by leave.” A copy of the claim of appeal must be filed with the Tribunal to certify the 

record on appeal. There is no certification fee. 

 

Entered: August 17, 2026 

 

 

 

By: /s/ Patricia L. Halm 

ejg 

 

PROOF OF SERVICE 

 

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives. 

By: Tribunal Clerk

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

STATE OF MICHIGAN 

 

GRETCHEN WHITMER 

GOVERNOR 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

LANSING 

MARLON I. BROWN, DPA 

DIRECTOR 

 

 

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 

Kuka Assembly & Test Corp, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

SMALL CLAIMS DIVISION 

 

v 

 

MTT Docket No. 26-000368 

 

Michigan Department of Treasury, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER GRANTING JUDGMENT IN FAVOR OF PETITIONER UNDER 

MCR 2.116(I)(1) 

 

FINAL OPINION AND JUDGMENT 

 

The Tribunal has reviewed the file in this case and finds that Petitioner filed this appeal 

on March 23, 2026, disputing the Decision and Order of Determination issued relative to 

Final Assessment Nos. 1474183, 1474184, 1474185, and 1474188, which was issued 

by Respondent on January 20, 2026. On June 8, 2026, Respondent filed an answer 

stating that Petitioner reached an agreement with the Audit Division regarding the 

amount of the determined liability and submitted payment as agreed. The settlement 

amount was not processed correctly by the Collections Division and the assessments 

were not properly reduced to match the amounts of the settlement agreement. The 

Revenue Services Division made corrections to the assessments to agree with the 

reduced amount of the settlement, and upon the corrections being processed, the 

Collections Division canceled the assessments. Several attempts have been made to 

contact Petitioner to advise them that the assessments have been cancelled but no 

response has been received. 

 

MCR 2.116(I)(1) states that “if the pleadings show that a party is entitled to judgment as 

a matter of law, or if the affidavits or other proofs show that there is no genuine issue of 

material fact, the court shall render judgment without delay.” Given that Respondent 

has indicated that the assessments have been cancelled, and that it has granted 

Petitioner the full extent of the relief requested in the petition, the Tribunal finds that 

judgment in favor of Petitioner is appropriate.1 Therefore, 

 

IT IS ORDERED that judgment is GRANTED in favor of Petitioner. 

 

IT IS FURTHER ORDERED that Final Assessment Nos. 1474183, 1474184, 1474185, 

and 1474188 are CANCELLED. 

 

1 Though Respondent requested dismissal of the case, this request is not properly pending because 

Respondent failed to file a motion accompanied by the appropriate fee, as required by TTR 231. 

Dismissal is also not warranted, as Respondent failed to file any documentation establishing that the 

requested relief has in fact been granted.

Page 2

MTT Docket No. 26-000368 

Page 2 of 2 

 

IT IS FURTHER ORDERED that Respondent shall cause its records to be corrected to 

reflect the taxes, interest, and penalties within 20 days of entry of this Final Opinion and 

Judgment. 

 

IT IS FURTHER ORDERED that Respondent shall collect the affected taxes, interest, 

and penalties or issue a refund as required by this opinion within 28 days of entry of this 

Final Opinion and Judgment. 

 

This opinion resolves the last pending claim and closes the case. 

 

APPEAL RIGHTS 

If you disagree with the final decision in this case, you may file a motion for 

reconsideration with the Tribunal or a claim of appeal with the Michigan Court of 

Appeals. 

 

A motion for reconsideration must be filed with the Tribunal with the required filing fee 

within 21 days from the date of entry of the final decision. Because the final decision 

closes the case, the motion cannot be filed through the Tribunal’s web-based e-filing 

system; it must be filed by mail or personal service. The fee for the filing of such 

motions is $50.00 in the Entire Tribunal and $25.00 in the Small Claims Division, unless 

the Small Claims decision relates to the valuation of property and the property had a 

principal residence exemption of at least 50% at the time the petition was filed or the 

decision relates to the grant or denial of a poverty or disabled veterans exemption and, 

if so, there is no filing fee. You are required to serve a copy of the motion on the 

opposing party by mail or personal service or by email if the opposing party agrees to 

electronic service, and proof demonstrating that service must be submitted with the 

motion. Responses to motions for reconsideration are prohibited and there are no oral 

arguments unless otherwise ordered by the Tribunal. 

 

Alternatively, you may file a claim of appeal with the Michigan Court of Appeals. If the 

claim is filed within 21 days of the entry of the final decision, it is an “appeal of right.” If 

the claim is filed more than 21 days after the entry of the final decision, it is an “appeal 

by leave.” A copy of the claim of appeal must be filed with the Tribunal to certify the 

record on appeal. There is no certification fee. 

 

Entered: August 17, 2026 

 

 

 

By: /s/ Patricia L. Halm 

ejg 

 

PROOF OF SERVICE 

 

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives. 

By: Tribunal Clerk

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

Kuka Assembly & Test Corp,

Petitioner,

MICHIGAN TAX TRIBUNAL

SMALL CLAIMS DIVISION

v 

MTT Docket No. 26-000368

Michigan Department of Treasury,

Respondent.

NOTICE OF FILING

TAKE NOTICE that a Small Claims answer has been filed and the electronic copy of the 

answer can be reviewed by utilizing the Docket Lookup on the Tribunal’s website. 

Unless Respondent was defaulted, this case is ready to be scheduled for a Small 

Claims hearing and will be scheduled in the normal course of scheduling. You will 

receive a Notice of Hearing from the Tribunal by e-mail if you have identified an email 

address in the petition or other documentation. The Notice of Hearing will inform you of 

the date, time, and location of your hearing (note that your hearing will likely be 

conducted by telephone). Please read the Notice of Hearing as it includes important 

information.

EVIDENCE: Parties are required to submit all evidence to the Tribunal and send a copy 

to the opposing party at least 21 days before the hearing date even if the documents 

had been submitted to the local Board of Review or the Michigan Department of 

Treasury. If the documents are not timely submitted to the Tribunal and served on the 

opposing party, the documents may be excluded. Documents may be filed with the 

Tribunal by mail or through the Tribunal’s e-filing system. Documents may be sent to the 

opposing party by mail or by e-mail, if the parties agree to service by e-mail.

Alternate Dispute Resolution Options

INFORMAL SETTLEMENT CONFERENCE: Parties have the option of handling this 

case through an informal settlement conference. An informal settlement conference 

is a meeting between the parties and/or their representatives to discuss the issues in a 

case in an effort to settle the case. This process may be an alternative to a hearing with 

a judge and may result in the parties’ filing a Joint Stipulation for Entry of Consent 

Judgment. Visit the Tribunal’s ADR webpage for more information.

NOTE: The parties may not request an informal settlement conference to discuss an 

appeal of a principal residence exemption that was denied by either the Michigan 

Department of Treasury or a County. Also, state taxes levied by the Michigan 

Department of Treasury, such as income taxes, are not subject to the informal 

settlement conference process.

Page 2

MTT Docket No. 26-000368

Page 2 of 2

MEDIATION: Parties have the option of handling this case through mediation. 

Mediation is a voluntary process where a mediator facilitates communication between 

the parties, assists in identifying issues, and helps explore solutions to promote a 

mutually acceptable settlement. This process may be an alternative to a hearing with a 

judge and may result in the parties’ filing a Joint Stipulation for Entry of Consent 

Judgment. Visit the Tribunal’s ADR webpage for more information.

If you have any questions, please contact the Tribunal by phone at (517) 335-9760 or 

email taxtrib@michigan.gov.

By: Tribunal Clerk

Entered: 

PROOF OF SERVICE

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives.

By: Tribunal Clerk

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

Kuka Assembly & Test Corp,

Petitioner,

MICHIGAN TAX TRIBUNAL

SMALL CLAIMS DIVISION

v 

MTT Docket No. 26-000368

Michigan Department of Treasury,

Respondent.

NOTICE OF FILING

TAKE NOTICE that a Small Claims answer has been filed and the electronic copy of the 

answer can be reviewed by utilizing the Docket Lookup on the Tribunal’s website. 

Unless Respondent was defaulted, this case is ready to be scheduled for a Small 

Claims hearing and will be scheduled in the normal course of scheduling. You will 

receive a Notice of Hearing from the Tribunal by e-mail if you have identified an email 

address in the petition or other documentation. The Notice of Hearing will inform you of 

the date, time, and location of your hearing (note that your hearing will likely be 

conducted by telephone). Please read the Notice of Hearing as it includes important 

information.

EVIDENCE: Parties are required to submit all evidence to the Tribunal and send a copy 

to the opposing party at least 21 days before the hearing date even if the documents 

had been submitted to the local Board of Review or the Michigan Department of 

Treasury. If the documents are not timely submitted to the Tribunal and served on the 

opposing party, the documents may be excluded. Documents may be filed with the 

Tribunal by mail or through the Tribunal’s e-filing system. Documents may be sent to the 

opposing party by mail or by e-mail, if the parties agree to service by e-mail.

Alternate Dispute Resolution Options

INFORMAL SETTLEMENT CONFERENCE:

Page 4

MTT

Page 5

STA

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Small Claims Division 

 

Kuka Assembly & Test Group 

 

 

Petitioner, 

v 

 

 

 

 

 

 

 

MTT Docket No. 26-000368 

 

MICHIGAN DEPARTMENT OF TREASURY, 

 

 

Respondent. 

______________________________ 

 

PROOF OF SERVICE 

 

 

Jennifer Maat states that on June 8, 2026, she served a copy of Respondent’s 

Answer upon Petitioner by both mailing and emailing it to Petitioner’s Representative 

and forwarding same to the Michigan Department of Treasury Mailroom for processing 

and including with the outgoing mail plainly: 

 

 

chris.wylie@kuka.com 

Christopher Wylie 

Kuka Assembly & Test Corp 

6600 Center Drive 

Sterling Heights, MI 48312 

 

 

 

 

Dated: 6/8/2026 

 

 

 

/s/ Jennifer Maat 

___________________________ 

 

 

 

 

 

 

Jennifer Maat, Litigation Analyst 

Michigan Department of Treasury 

Bureau of Tax Policy

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Page 1

1 of 1

Docket #: 26-000368

Party Filing Document

Party Filing Document: 

 Respondent

 Respondent

 

 

If 'other', Identify: 

File

Document Type: 

 

 

fuFile:

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Page 1

RESPONSE TO PETITIONER’S REASON FOR APPEAL 

MTT Docket No. 26-000368 

USE TAX 

KUKA ASSEMBLY & TEST CORP., 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 Kuka 

Assembly & Test Corp. (“Petitioner”). A copy of this answer has been served concurrently 

on the Petitioner. 

Petition 

Petitioner is appealing the intents to assess, relating to a use tax audit that was 

conducted for tax periods December 2020 through December 2023. 

Background 

A use tax audit was conducted on Petitioner and resulted in the issuance of four intents 

to assess; assessment numbers 1474183, 1474184, 1474185, and 1474188. 

Petitioner’s Claims 

Petitioner claims that it requested, and was granted, an informal conference upon 

receiving the intents to assess. Petitioner further claims that prior to the hearing being 

conducted, it reached an agreement with the Audit Division regarding the amount of the 

determined liability, which was less than previously determined, to satisfy all four 

assessments and immediately paid the settlement amount. 

Respondent’s Answer 

Treasury has reviewed all information supplied by Petitioner and has completed a 

thorough review of the Petitioner’s account history. On or around March of 2025, the 

Revenue Services Division of the Michigan Department of Treasury concluded a use tax 

audit for periods ranging from December 2020 through December 2023. The audit 

resulted in a use tax balance due for four different periods and subsequently, Intents to 

Assess were issued. Petitioner requested, and was granted, an informal conference to 

contest the balances. Prior to the hearing being conducted, it reached an agreement 

with the Audit Division regarding the amount of the determined liability. Petitioner 

submitted the payment, as agreed. However, a balance remained due on the 

assessments and Petitioner continued to receive notices. Upon review by Treasury, it 

was determined that the settlement amount was not processed correctly by the 

Collections Division and the assessments were not properly reduced to match the 

amounts of the settlement agreement.

Page 2

Relief 

The Revenue Services Division of the Department of Treasury has made corrections to 

the assessments to agree with the reduced amount of the settlement. Upon the 

corrections being processed, the Collections Division was able to cancel assessment 

numbers 1474183, 1474184, 1474185, and 1474188. Several attempts have been 

made to contact Petitioner to advise them that the assessments have been cancelled 

but no response has been received. The Department has granted Petitioner the full 

extent of relief as requested in the Petition and requests that this case be dismissed.

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

TAX APPEAL ANSWER FORM

NON-PROPERTY TAX

MTT DOCKET NO. 26-000368

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government:

Michigan Department of Treasury (MDT)

First Name

M.I.

Last Name

Home Address (No., Street, P.O. Box or Rural Route)

City or Town

State

ZIP Code

Telephone Number

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)

Section 2: Respondent’s Attorney/Authorized Representative’s Contact Information

First Name

Julie

M.I.

Last Name

Jensen

Firm Name (if any)

Michigan Department of Treasury

Address (No., Street, P.O. Box or Rural Route)

PO Box 30828

City or Town

Lansing

State

Michigan

ZIP Code

48909

Telephone Number

517-335-7478

E-mail Address

jensenj@michigan.gov

 

Section 3: Explain Your Answer to this Appeal

Pursuant to Michigan Tax Tribunal Rule (TTR) 277(3), you MUST submit a copy of the notice giving rise to the appeal (e.g. notice of action taken by the Michigan 

Department of Treasury) with this Small Claims Answer, if applicable. If you do not submit this document, you may be held in default.

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

See attachment to answer.

 

Section 4: Assessment Information

Type of Tax Being Assessed:

Use Tax

Assessment Number(s):

1474183,1474184,1474185 &1474188

Check what action prompted this appeal: (Check one)

Other

If “other,” explain:

Pre-Informal Conference, Documents In Review resolution

List when the Final Assessment, Letter Denying Refund, or other action was issued:

2025-03-31

List the amounts levied:

Tax 17758

Interest 4664

Penalty 1776

List your contentions: 

Tax 0

Interest 0

Penalty 0

What is the basis and statutory authority for the tax assessment:

MCL 205.91 et seq

Electronic Signature *Typing your name below will serve as your signature

Respondent or Attorney/Authorized Representative’s Signature: 

Julie Jensen 

/s/

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

TAX APPEAL PETITION FORM

NON-PROPERTY TAX

MTT DOCKET NO. 

Section 1: Petitioner’s Contact Information

Filer Type: Organization

First Name

 Kuka Assembly & Test Corp

M.I.

Last Name/Company Name

Kuka Assembly & Test Corp

Mailing Address (No., Street, P.O. Box or Rural Route)

6600 Center Drive

City or Town

Sterling Heights

State

Michigan

ZIP Code

48312

Telephone Number

248-207-5555

Fax Number

E-mail Address

chris.wylie@kuka.com

Section 2: Petitioner’s Attorney/Authorized Representative’s Contact Information

First Name

Christopher

M.I.

P

Last Name

Wylie

Firm Name (if any)

Address (No., Street, P.O. Box or Rural Route)

17963 Maple Hill Court

City or Town

Northville

State

Michigan

ZIP Code

48168

Telephone Number

248-773-5091

Fax Number

480-772-4073

E-mail Address

cpw@wyliegroup.us

Pursuant to Michigan Tax Tribunal Rule (TTR) 277(3), you MUST submit a copy of the notice giving rise to the appeal (e.g. notice of action taken by the 

Michigan Department of Treasury) with this Small Claims Petition, if applicable. If you do not submit this document, you may be held in default.

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Section 3: Explain the Reason for this Appeal

A failure of the audit and collections divisions to coordinate the resolution of an

audit as agreed to by the parties.

This followed a Use Tax audit. Petitioner filed a request for an informal conference but an agreement was reached on final amounts due which were promptly paid.

Michigan Collections misapplied the amounts paid and left a balance due where there should be none.

Section 4: Assessment Information

Type of Tax Being Assessed:

Assessment Number(s):

Check all that are being appealed:

Check what action prompted this appeal: (Check one)

If “other,” explain:

List the Amounts being levied:

Tax 0

Interest 8928.79

Penalty 0

List the refund sought, if any:

List your Contentions: 

Tax 0

Interest 0

Penalty 0

Fee Information

A fee of $100.00 is required for the filing of a Non-Property Tax Appeal.

Electronic Signature *Typing your name below will serve as your signature

Petitioner or Attorney/Authorized Representative’s Signature: 

Christopher P. Wylie

/s/

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

Kuka Assembly & Test Corp,

Petitioner,

MICHIGAN TAX TRIBUNAL

SMALL CLAIMS DIVISION

v 

MTT Docket No. 26-000368

Michigan Department of Treasury,

Respondent.

NOTICE OF DOCKET NUMBER

TAKE NOTICE that a Small Claims petition has been filed and the above-noted docket 

number has been assigned to that petition. The assignment of the docket number does 

not mean that the Tribunal has authority over the petition or that the petition complies 

with the Tribunal’s rules. The docket number needs to be included on all documents 

submitted in this case.

Respondent shall file an answer to the petition within 28 days of the issuance of a 

copy of this Notice to Respondent. Tribunal answer forms are available on our 

website at www.michigan.gov/taxtrib. Respondents must utilize the appropriate answer 

form. Failure to file the answer within the 28-day time frame may result in the 

placement of Respondent in default, as provided by TTR 281. Further, an electronic 

copy of the petition can be reviewed by utilizing the Docket Lookup Search on the 

Tribunal’s website.

By: __Tribunal Clerk_____

Entered: May 11, 2026

PROOF OF SERVICE

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives.

By: Tribunal Clerk

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

Kuka Assembly & Test Corp,

Petitioner,

MICHIGAN TAX TRIBUNAL

SMALL CLAIMS DIVISION

v 

MTT Docket No. 26-000368

Michigan Department of Treasury,

Respondent.

NOTICE OF DOCKET NUMBER

TAKE NOTICE that a Small Claims petition has been filed and the above-noted docket 

number has been assigned to that petition. The assignment of the docket number does 

not mean that the Tribunal has authority over the petition or that the petition complies 

with the Tribunal’s rules. The docket number needs to be included on all documents 

submitted in this case.

Respondent shall file an answer to the petition within 28 days of the issuance of a 

copy of this Notice to Respondent. Tribunal answer forms are available on our 

website at www.michigan.gov/taxtrib. Respondents must utilize the appropriate answer 

form. Failure to file the answer within the 28-day time frame may result in the 

placement of Respondent in default, as provided by TTR 281. Further, an electronic 

copy of the petition can be reviewed by utilizing the Docket Lookup Search on the 

Tribunal’s website.

By: __Tribunal Clerk_____

Entered: May 11, 2026

PROOF OF SERVICE

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives.

By: Tribunal Clerk

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Page 1

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

Page 2

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

Page 3

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

Page 4

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

Page 5

5753

Page 7

USP

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

TAX APPEAL PETITION FORM

NON-PROPERTY TAX

MTT DOCKET NO. 

Section 1: Petitioner’s Contact Information

Filer Type: Organization

First Name

 Kuka Assembly & Test Corp

M.I.

Last Name/Company Name

Kuka Assembly & Test Corp

Mailing Address (No., Street, P.O. Box or Rural Route)

6600 Center Drive

City or Town

Sterling Heights

State

Michigan

ZIP Code

48312

Telephone Number

248-207-5555

Fax Number

E-mail Address

chris.wylie@kuka.com

Section 2: Petitioner’s Attorney/Authorized Representative’s Contact Information

First Name

Christopher

M.I.

P

Last Name

Wylie

Firm Name (if any)

Address (No., Street, P.O. Box or Rural Route)

17963 Maple Hill Court

City or Town

Northville

State

Michigan

ZIP Code

48168

Telephone Number

248-773-5091

Fax Number

480-772-4073

E-mail Address

cpw@wyliegroup.us

Pursuant to Michigan Tax Tribunal Rule (TTR) 277(3), you MUST submit a copy of the notice giving rise to the appeal (e.g. notice of action taken by the 

Michigan Department of Treasury) with this Small Claims Petition, if applicable. If you do not submit this document, you may be held in default.

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Section 3: Explain the Reason for this Appeal

A failure of the audit and collections divisions to coordinate the resolution of an

audit as agreed to by the parties.

This followed a Use Tax audit. Petitioner filed a request for an informal conference but an agreement was reached on final amounts due which were promptly paid.

Michigan Collections misapplied the amounts paid and left a balance due where there should be none.

Section 4: Assessment Information

Type of Tax Being Assessed:

Assessment Number(s):

Check all that are being appealed:

Check what action prompted this appeal: (Check one)

If “other,” explain:

List the Amounts being levied:

Tax 0

Interest 8928.79

Penalty 0

List the refund sought, if any:

List your Contentions: 

Tax 0

Interest 0

Penalty 0

Fee Information

A fee of $100.00 is required for the filing of a Non-Property Tax Appeal.

Electronic Signature *Typing your name below will serve as your signature

Petitioner or Attorney/Authorized Representative’s Signature: 

Christopher P. Wylie

/s/

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.