Underlying Sales Tax Assessments Had Become Final and Were Not Appealed
In Baas v. Department of Treasury, Michigan Tax Tribunal, No. 385112, January 13, 2012, assessments for unpaid Michigan sales tax were upheld against the taxpayer's corporate officer because the underlying assessments against the taxpayer were not appealed and had become final. The corporate officer did not dispute that he was indeed a responsible officer during the relevant period. His challenge concerned the amount of the underlying assessments. However, the assessments against the taxpayer were final and therefore were not open to challenge. The officer's liability was derivative of the liability of the corporate taxpayer.