Wells Fargo Rail Corp. challenged a denial of tax credits in the wrong court due to a “preexisting jumble” of conflicting statutes, the Michigan Court of Appeals ruled.
The company had no way to know that the statute it used to identify the appropriate court to direct its state tax bill challenge to was implicitly repealed by a later statute, Judge Noah P. Hood wrote for the court in an opinion issued Thursday. It may refile its suit in the Michigan Tax Tribunal without worrying about the expired statute of limitations, the court ruled.