Record Finder / 26-000665-TT
Michigan
Snf Holdings LLC / Dba Vios Compounding Pharmacy Petitioner Vs. Michigan Department Of Treasury Respondent
- Petitioner
- Snf Holdings LLC / Dba Vios Compounding Pharmacy
- Respondent
- Michigan Department Of Treasury
Case overview
- Docket number
- 26-000665-TT
- Status
- Ready Schedule
- CaseType
- SC Non-Property
- Division
- Small Claims Division
- County
- Wayne
- Judge
- No judge assigned
Docket history
| Line # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 7 | Notice of Filing | Not recorded | Not recorded | 09/25/2026 | Not recorded | Download |
| 6 | Proof of Service of Misc Documents was received. | RESP | Not recorded | 07/31/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 5 | Answer was received | RESP | Not recorded | 07/31/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 4 | Petition has been verified | Not recorded | 1 | 07/13/2026 | Not recorded | Download |
| 3 | Notice of Docket Number SC | Not recorded | Not recorded | 07/09/2026 | Not recorded | Download |
| 2 | Attachments to the Petition were filed | Not recorded | Not recorded | 04/20/2026 | Not recorded | Download |
| 1 | A petition was received. | Not recorded | Not recorded | 04/20/2026 | $100.00 | Download |
Documents
SC-Notice_of_Filing_of_Answer.2026-09-25_15-45-04.pdfRead complete document text →
Read document text excerpt
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 SNF Holdings LLC / dba Vios Compounding Pharmacy, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 26-000665 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. 26-000665 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 SNF Holdings LLC / dba Vios Compounding Pharmacy, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 26-000665 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
Page 4
MTT
Page 5
STATE
Page 6
M
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.
26-000665 SNF Holdings proof.pdfRead complete document text →
Read document text excerpt
Page 1
STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Small Claims Division SNF Holdings LLC/ dba Vios Compounding Pharmacy, Petitioner, v MTT Docket No. 26-000665 Michigan Department of Treasury, Respondent. ______________________________ PROOF OF SERVICE Jennifer Maat states that on July 31, 2026, she served a copy of Respondent’s Answer and Motion to Transfer to the Entire Tribunal 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: sammy@vioscompounding.com Sammy Salem Vios Compounding Pharmacy 31035 Schoolcraft Livonia, MI 48150 Dated: 7/31/2026 /s/ Jennifer Maat ___________________________ Jennifer Maat, Litigation Analyst Michigan Department of Treasury Bureau of Tax Policy
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.
SubsequentFiling.pdfRead complete document text →
Read document text excerpt
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 MICHIGAN TAX TRIBUNAL Docket Number: 26-000665 Is this case currently pending in the Small Claims Division? Yes Party Filing Document Respondent Files Document Type: Proof of Service: Misc Documents Attachment File Name: 26-000665 SNF Holdings proof Fee Information Filing Fee: $ 0.00
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.
26-000665 SNF Holdings Answer.pdfRead complete document text →
Read document text excerpt
Page 1
ANSWER/MOTION TO TRANSFER SNF Holdings LLC dba Vios Compounding Pharmacy v Treasury MTT Docket No. 26-000665 Corporate Income Tax Act, MCL 206.601 et seq. Rejection of tentative claim for research and development credit, 2025 Filing The Tax Policy Division, Michigan Department of Treasury, submits this answer in response to a petition filed with the Small Claims Division of the Michigan Tax Tribunal by SNF Holdings LLC. A copy of this answer has been served concurrently on Petitioner. Petition Petitioner is appealing the rejection of its tentative claim for the research and development (R&D) credit under MCL 206.677. As Petitioner admits in the petition, Petitioner filed the tentative claim after the statutory deadline. The deadline was April 1, 2026. MCL 206.677(3). Petitioner filed its tentative claim on April 8, 2026. Exhibit A. Background Under MCL 206.677(1), a taxpayer can claim a credit for a portion of their R&D expenses incurred during the calendar year ending within the tax year. To claim the credit for expenses incurred in calendar year 2025, the taxpayer first “must submit . . . a tentative claim . . . to the department on or before April 1, 2026.” MCL 206.677(3). The credit is subject to an aggregate annual cap. MCL 206.677(5). Treasury is required to review all tentative claims and, if the total value of those claims exceeds the annual cap, to prorate the credit each taxpayer can claim on their annual return. MCL 206.677(4), (5). Treasury must publish the proration rate on its website. MCL 206.677(4). In this case, Petitioner emailed Treas_Tax_Policy@michigan.gov on April 8, 2026, seven days after the deadline for filing a tentative claim, attaching a copy of a document entitled R&D Tax Credit Study. Exhibit A at 5-6. The next day, April 9, 2026, Treasury responded to the email, asking for confirmation that the document was intended as a tentative claim for the R&D credit. Id. at 2. Petitioner responded to the email the same day, stating that the document was intended as a tentative claim for the credit. Id. at 1. Treasury sent Petitioner a letter dated April 20, 2026, stating that Petitioner’s tentative claim was rejected because it was filed after the deadline of April 1, 2026. Exhibit B. On April 24, 2026, Treasury published the required proration notice, having completed the required review of tentative claims for the year and concluded that proration was required. https://www.michigan.gov/treasury/reference/taxpayer- notices/2026/04/24/research-and-development-credit-proration-notice-for-credits-based- on-2025-expenses. 001
Page 2
Respondent’s Answer 1. The petition should be dismissed because Petitioner has not stated a claim on which relief can be granted. Treasury requests that the Tribunal dismiss the petition because Petitioner has not stated a claim on which relief can be granted. Petitioner is asking the Tribunal to set aside the deadline set by MCL 206.677(3). The Tribunal does not have the authority to set aside a statutory deadline because the Tribunal does not have the authority to grant equitable relief. Marie De Lamielleure Trust v Treasury, 305 Mich App 282, 288 (2014). In De Lamielleure, the Court of Appeals held that, because the Tribunal lacked equitable authority, it could not stop Treasury from assessing statutorily required property taxes, even though Treasury had erroneously failed to assess the taxes previously. 305 Mich App at 287-288. Similarly, here, the Tribunal does not have the equitable authority to require Treasury to disregard the statutorily required deadline for tentative R&D claims. Even if the Tribunal had equitable authority, it could not use it to override an unambiguous statutory requirement such as the deadline here. See Stokes v Millen Roofing, 466 Mich 660, 671-672 (2002) (“Regardless of how unjust the statutory penalty might seem to this Court, it is not our place to create an equitable remedy for a hardship created by an unambiguous, validly enacted legislative decree” (internal quotations omitted).). The statutory deadline at issue here is key in effectuating the proration requirement for the R&D credit; without the deadline, neither Treasury nor taxpayers would have finality as to the prorated amount of credit a taxpayer was entitled to claim. 2. Alternatively, the case should be transferred to the entire Tribunal. If the Tribunal does not dismiss the petition, Treasury requests that the Tribunal transfer the case from the Small Claims Division to the entire Tribunal. Treasury requests that the Tribunal consider this portion of Treasury’s answer to be a motion to transfer under Rule 792.10275, which allows any party to request a transfer from the Small Claims Division to the entire Tribunal. The Small Claims Division does not have jurisdiction over this case. Petitioner is claiming $44,452.00, which exceeds the monetary threshold for Small Claims jurisdiction. In non-property tax cases such as this one, Small Claims jurisdiction is limited to amounts in dispute up to $20,000, adjusted for inflation. Mich Admin Code R 792.10265; MCL 205.762(1). For 2026, the maximum amount in dispute for a Small Claims case is $31,162.00. Because Petitioner is claiming more than this amount, the Small Claims Division does not have jurisdiction, and the case should be transferred to the entire Tribunal. 002
Page 3
Relief Requested Treasury requests that the Tribunal dismiss the petition. In the alternative, Treasury requests that the Tribunal transfer this case from the Small Claims Division to the entire tribunal. /s/ David Foos 7/30/2026 David Foos, Administrator Michigan Department of Treasury Bureau of Tax Policy Direct Taxes Division 003
Page 4
From: Sammy Salem <sammy.salem@vioscompounding.com > Sent: Thursday, April 9, 2026 10:49 AM To: Foos, David (TREASURY) <FoosD@michigan.gov >; belal@omnextax.com Subject: Re: R & D Credit for Vios Compounding CAUTION:
Page 5
You
Page 6
O
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.
scanswer_nonprop.pdfRead complete document text →
Read document text excerpt
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. 26-000665 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 David M.I. Last Name Foos Firm Name (if any) Department of Treasury Address (No., Street, P.O. Box or Rural Route) P O Box 30828 PO Box 30828 City or Town Lansing State Michigan ZIP Code 48909 Telephone Number 517-335-7478 E-mail Address foosd@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 and motion to transfer. Section 4: Assessment Information Type of Tax Being Assessed: Corporate Income Tax Assessment Number(s): Claim for R & D credit Check what action prompted this appeal: (Check one) Other If “other,” explain: Claim for R & D credit List when the Final Assessment, Letter Denying Refund, or other action was issued: 2026-04-08 List the amounts levied: Tax 44452 Interest 0 Penalty 0 List your contentions: Tax 44452 Interest 0 Penalty 0 What is the basis and statutory authority for the tax assessment: Corporate Income Tax MCL 206.601 et seq Electronic Signature *Typing your name below will serve as your signature Respondent or Attorney/Authorized Representative’s Signature: David Foos /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.
04._Tax_Appeal_Petition_Form_Non-Property.0b23a14f-c573-4d71-8f3b-db2d8fd5bdce.pdfRead complete document text →
Read document text excerpt
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 SNF Holdings llc / dba Vios Compounding Pharmacy M.I. Last Name/Company Name SNF Holdings llc / dba Vios Compounding Pharmacy Mailing Address (No., Street, P.O. Box or Rural Route) 31035 Schoolcraft Road City or Town Livonia State Michigan ZIP Code 48150 Telephone Number 3139999499 Fax Number E-mail Address sammy@vioscompounding.com Section 2: Petitioner’s Attorney/Authorized Representative’s Contact Information First Name Sammy M.I. Last Name Salem Firm Name (if any) Address (No., Street, P.O. Box or Rural Route) 31035 Schoolcraft City or Town Livonia State Michigan ZIP Code 48150 Telephone Number 313-999-9499 Fax Number E-mail Address sammy@vioscompounding.com 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 This is an appeal to be filed for R&D Tax credit filing. We now understand that the statute states that the deadline to be filed was April 1st, however at the time of the filing we did not. Through various attempts on March 31st and on April 1st, our CPA claims to have tried to submit, however, had technical issues. In any case, it was brought to my attention on April 3rd where the CPA had notified about the deadline passing. We had reached out to the treasury department and submitted the filing via email and the response is attached denying the submission due to being 2 days late. 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 0 Penalty 0 List the refund sought, if any: 44452.00 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: Sammy Salem /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.
SC_Notice_of_Docket_Number.2026-07-09_06-50-56.pdfRead complete document text →
Read document text excerpt
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 SNF Holdings LLC / dba Vios Compounding Pharmacy, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 26-000665 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: July 9, 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 SNF Holdings LLC / dba Vios Compounding Pharmacy, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 26-000665 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: July 9, 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 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 SNF Holdings LLC / dba Vios Compounding Pharmacy, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 26-000665 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: July 9, 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
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.
ATL NF 22330 R &D Credit for Vios Compounding - final signed.pdfRead complete document text →
Read document text excerpt
Page 1
430 WEST ALLEGAN STREET • LANSING, MICHIGAN 48922 www.michigan.gov/treasury • 517-335-7508 GRETCHEN WHITMER GOVERNOR STATE OF MICHIGAN DEPARTMENT OF TREASURY LANSING RACHAEL EUBANKS STATE TREASURER April 20, 2026 Sammy Salem, COO SNF Holdings, LLC d/b/a Vios Compounding 31035 Schoolcraft Road Livonia, MI 48150 Re: Rejection of Michigan Research and Development Credit Tentative Claim Submission Dear Mr. Salem: This letter is in response to the April 8, 2026 email submission of a Michigan research and development credit tentative claim by Belal Majed on behalf of SNF Holdings, LLC d/b/a Vios Compounding (“Taxpayer”). As provided in MCL 206.677(3) and MCL 206.717(3), and as described in RAB 2026-4, to be eligible for a Michigan research and development credit for qualified research and development expenses incurred in 2025, claimants had to submit their tentative claims by April 1, 2026. Because Taxpayer submitted its tentative claim after this deadline, its claim has been rejected. If you disagree with this decision, you may file your written appeal as follows: 1. Within 60 days, to the Michigan Tax Tribunal. See www.michigan.gov/taxtrib for information, including the required Petition and filing fee. 2. Within 90 days, to the Michigan Court of Claims. See courts.michigan.gov/courts/court-of- claims for information, including the required Summons and Complaint and filing fee. Sincerely, /s/ David Matelski David Matelski Director, Bureau of Tax Policy CC: Belal Majed 72 (Rev. 03-19)
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.
04._Tax_Appeal_Petition_Form_Non-Property.0b23a14f-c573-4d71-8f3b-db2d8fd5bdce.pdfRead complete document text →
Read document text excerpt
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 SNF Holdings llc / dba Vios Compounding Pharmacy M.I. Last Name/Company Name SNF Holdings llc / dba Vios Compounding Pharmacy Mailing Address (No., Street, P.O. Box or Rural Route) 31035 Schoolcraft Road City or Town Livonia State Michigan ZIP Code 48150 Telephone Number 3139999499 Fax Number E-mail Address sammy@vioscompounding.com Section 2: Petitioner’s Attorney/Authorized Representative’s Contact Information First Name Sammy M.I. Last Name Salem Firm Name (if any) Address (No., Street, P.O. Box or Rural Route) 31035 Schoolcraft City or Town Livonia State Michigan ZIP Code 48150 Telephone Number 313-999-9499 Fax Number E-mail Address sammy@vioscompounding.com 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 This is an appeal to be filed for R&D Tax credit filing. We now understand that the statute states that the deadline to be filed was April 1st, however at the time of the filing we did not. Through various attempts on March 31st and on April 1st, our CPA claims to have tried to submit, however, had technical issues. In any case, it was brought to my attention on April 3rd where the CPA had notified about the deadline passing. We had reached out to the treasury department and submitted the filing via email and the response is attached denying the submission due to being 2 days late. 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 0 Penalty 0 List the refund sought, if any: 44452.00 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: Sammy Salem /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.